NC0006033_Fact Sheet_20211201

Fact Sheet
NPDES Permit No. NC0006033
Permit Writer / Email Contact Diana Yitbarek / [e-mail]
Date: 12/ 1 /2021
Division/Unit: NC DEQ Division of Water Resources / NPDES Municipal Permitting Unit
Fact Sheet Template: Version 1/9/2017
Permitting Action:
❑X Renewal
❑ Renewal with Expansion
❑ New Discharge
❑ Modification (Fact Sheet should be tailored to mod request)
1. Basic Facility Information
Table 1. Facility Information
Facility Information
Applicant/Facility Name:
Two Rivers Utilities/Eagle Road Wastewater Treatment Plant (WWTP)
Applicant Address:
PO Box 1748, Gastonia, NC 28053
Facility Address:
661 Eagle Road, Belmont NC 28012
Permitted Discharge Flow:
4.0 million gallons per day (MGD)
Facility Type/Waste:
Major Municipal/ Domestic
Facility Class:
Class IV Biological - 15A NCAC 08G .0302
Treatment Units:
Influent mechanical bar screen, emergency storage basin, one aeration basin,
two secondary clarifiers, chlorine contact chamber, dechlorination/sodium
bisulfite, post aeration, aerobic digester, and two standby generators.
Pretreatment Program
(Y/N/Inactive)
Inactive
County:
Gaston
Region:
Mooresville Regional Office (MRO)
Permitting Action: This Facility is owned by the City of Gastonia and operated and maintained by Two Rivers
Utilities (TRU). TRU applied for the NPDES permit renewal for Eagle Road WWTP in August 2019. The WWTP
has a design capacity of 4.0 MGD and is currently authorized to discharge 4.0 MGD into South Fork Catawba
River, classified as WS-V. The class denotes use as water supply. The Eagle Road WWTP (Facility) serves about
6,700 customers within the Towns of Cramerton, Kings Grant, and Belmont. The pretreatment program is inactive
since 2006. The Facility provided June 2020 IWS for the entire area covered by the City of Gastonia's three
WWTPs. One non -significant industrial user (NSIU) in the City of Belmont (Syncot Fibers and Plastics — SIC
Code 2299) discharges into Eagle Road WWTP. Syncot Fibers and Plastics is regulated through the City of
Belmont's pretreatment program.
In 2017, TRU's staff expressed concerns about unusual plastic material in the biosolids in the digesters and the
lagoons. TRU solved this issue in a process that took from December 2017 to April 2020. The process included
Page 1 of 19

assessing the impacted residuals on Gastonia's permitted land; installing temporary filtering systems to capture
plastics and glass fibers to prevent plastic particles from escaping in the effluent and installing pretreatment for
glass fibers at the industry that caused the issue at Eagle Road WWTP, Syncot Plastics. The resulting glass fiber
contaminated biosolids from the digesters, and biosolids at both Eagle Road WWTP and Long Creek WWTP
were pressed and landfilled.
May 8, 2018, TRU's letter requested the addition of supplemental nutrient allocation, 144 lbs/day of TN and
7.6 lbs/day of TP, purchased from NC0005274 (Lowell Investments) to Eagle Road WWTP's permit.
August 1, 2019, TRU's cover letter for renewal application requested that the rescinded NPDES permit
NC0004812's allocation for 50 lb/day of TN and 8.3 lb/day of PT be added to Eagle Road WWTP's permit,
reduce monitoring frequency for BOD5, TSS, ammonia, and fecal coliform to twice per week, and reduce instream
monitoring to once per week. These requests are addressed below in this fact sheet.
Facility Background: The Facility was initially permitted to JPS Auto Products, a textile facility. The Town of
Cramerton purchased the Facility in 1999. In 2011 the Town of Cramerton and the City of Gastonia merged
their utility systems. The Eagle Road WWTP continues to operate as a secondary treatment plant with chemical
phosphorus removal with aluminum chlorohydrate. Since the last permit renewal, the aeration basin curtain was
replaced.
2. Receiving Waterbody Information:
Table 2. Receiving Waterbodv Information
Outfalls/Receiving Stream(s):
Outfall 001 [35°14'O1 "N 81°03'52" W]/South Fork Catawba River
Stream Segment/Assessment
Unit (AU):
11-129-(15.5)
Stream Classification:
WS-V
Drainage Area (mi2):
635*
Summer 7Q10 (cfs)
125*
Winter 7Q10 (cfs):
230*
30Q2 (cfs):
309*
Average Flow (cfs):
810*
Instream Waste Concentration
(IWC) (% effluent):
4.7% at 4.0 MGD (7Q10S)
303(d) listed/parameter:
Yes - 2020 303(d) list/ Turbidity
Subject to TMDL/parameter:
Yes - Mercury Statewide TMDL implemented in 2012
Yes — Nitrogen and Phosphorous - Lake Wylie TMDL 1995 Catawba
River Basinwide Water Quality Management Plan
Basin/Sub-basin/ Hydrologic unit
code (HUC):
Catawba River Basin/03-08-36/0305010206
USGS Topo Quad/State Grid:
Mount Holly/F14SE
*Low Flow values taken from previous spreadsheets per Division Guidelines. (2002 — 2016)
Page 2 of 19

This Facility is subject to 1995 Lake Wylie's total maximum daily load (TMDL), a nutrient control management
strategy for the Lake Wylie watershed. The TMDL strategy included requirements for facilities to meet stringent
nutrient removal goals. Long Creek WWTP undertook significant improvements to meet the nutrient limits.
The receiving stream, South Fork Catawba River, was recently listed in the NC 2020 303(d) list for turbidity
(50 Nephelometric Turbidity Units (NTU), AL, FW miles). This stream is located from a point 0.4 mile
upstream of Long Creek to Cramerton Dam and Lake Wylie at Upper Armstrong Bridge. The Division expects
that the TSS loading limit for discharges to streams impaired for turbidity should not be allowed to increase.
When a TMDL is established, TSS permit loading limits will be revised to be consistent with any waste load
allocation.
3. Effluent Data Summary
Effluent data for Outfall 001 is summarized below from May 2016 through March 2021.
Table 3. Effluent Data Summary with permit limits Outfall 001. Parameters listed as in the last permit.
Parameter
Units
Average
Max.
Min.
Permit Limit
Flow
MGD
0.8
3.02
0.09
MA* 4.0 MGD
BOD5
mg/1
3.5
24.4
2.0
MA 10.0 mg/1
WA* 15.0 mg/1
Total Suspended
Solids (TSS)
m /1
g
3.2
17.4
2.5
MA 30.0 mg/1
WA 45.0 mg/1
NH3N
mg/1
0.27
12.7
0.1
MA 4.0 mg/1
WA 12.0 mg/1
Total Residual
Chlorine (TRC)
µg/1
21.1
49
20
DM* 28.00 µg/1
Fecal Coliform
#/100 ml
8.02
(Geomean)
2700
1.00
MA 200/100m1
WA 400/100m1
Dissolved Oxygen
(DO)
m /1
g
9.74
14.3
6.1
Temperature
°C
18
28
3
Total Hardness
mg/1
42.05
50.0
32.0
pH
SU
7.1
7.7
4.1
6.0<pH59.0
TKN
mg/1
0.96
2.8
0.1
NO3-N + NO2-N
mg/1
24.06
43.2
10.8
Total Nitrogen (TN)
mg/1
24.2
43.2
10.8
TN Load
lb/month
4873.3
7863.0
3786.0
TN Load
lb/season
17,670.8
37,973.0
4,193.0
42,834 lb/season (S)
60,448 lb/season (W)
Total Phosphorus (TP)
mg/1
0.75
9.3
0.1
MA 1.0 mg/1
TP Load
lb/month
207.3
1023.0
40.0
TP Load
lb/year
1589.0
3784.0
114.0
12,1761b/yr
*MA -Monthly Average, WA -Weekly Average, DM -Daily Maximum, DA=Daily Average.
Table 4. Effluent Data Summary from expanded effluent pollutant scan Outfall 001
Parameter
Units
Average
Max.
Arsenic
µg/1
1.4
2.2
Chromium
µg/1
1.4
2.2
Copper
µg/1
4.4
5.2
Mercury*
ng/1
1.26
1.62
Page 3 of 19

Nickel
µg/1
1.8
2.4
Zinc
µg/1
31.6
42.0
Chloroform
µg/1
21.3
25.0
Chlorodibromomethane
µg/1
1.7
2.2
Dichlorodibromomethane
µg/1
5.6
7.0
Total Phenolic
Compounds
lag/16.4
11.0
Conductivity**
umhos/cm
465.2
531
*See section 6.6 Mercury Statew.de Total Maximum Daily Load (TMDL) Evaluation
**Voluntarily collected in 2016 and 2017
Sample results for the sampled metals not included above, such as beryllium, cadmium, cyanide, lead,
molybdenum, selenium, silver, and thallium, were less than the method detection limit. The compounds in the
above table were analyzed in the reasonable potential analysis (RPA) and discussed below in the RPA section
of this fact sheet.
4. Instream Data Summary
Instream monitoring may be required in certain situations, for example, 1) to verify model predictions when
model results for instream DO are within 1 mg/1 of instream standard at full permitted flow; 2) to verify model
predictions for outfall diffuser; 3) to provide data for future total maximum daily load (TMDL); 4) based on
other instream concerns. Instream monitoring may be conducted by the Permittee, and there are also Monitoring
Coalitions established in several basins that conduct instream sampling for the Permittee (in which case
instream monitoring is waived in the permit as long as coalition membership is maintained).
Instream data summary and instream monitoring proposed for this permit action:
The current permit requires instream [upstream (U) and downstream (D)] monitoring for dissolved oxygen,
temperature, and hardness at one upstream location and one downstream location. The U location is about 1000
feet above the outfall at Cramerton Bridge on North Main Street. The D location is about 1.5 miles from the
outfall at Armstrong Ford Road. The figure below summarizes instream and effluent data from the analyzed
period, May 2016 - March 2021.
Figure 1. Average, maximum, and minimum instream and effluent data summary
35.0
30.0
25.0
20.0
15.0
10.0
5.0
0.0
Temperature, °C
Upstream
■ Average 20.6
• Max 31.7
• Min 1.0 3.0
Effluent
18.0
28.0
Downstream
20.6
31.0
2.0
16.0
14.0
12.0
10.0
8.0
6.0
4.0
2.0
0.0
Upstream
■ Average 8.9
• Max 15.0
■ Min 6.6
DO, mg/I
Effluent Downstream
9.7
14.3
6.1
8.8
14.6
6.5
T-tests were run to analyze relationships between instream sample results. A statistically significant
difference is determined when the t-test p-value result is < 0.05.
Page 4 of 19

DO: The minimum downstream DO detected was 6.5 mg/1, and the maximum DO differential between the
upstream and downstream samples was 2.2 mg/1. Instream DO was consistently above the standard of 5 mg/1
[per 15A NCAC 02B .0211 (6)] at both the upstream and downstream sampling sites throughout the period
reviewed. Also, per the t-test was concluded that there is no statistically significant difference between
upstream and downstream DO.
Temperature: The maximum downstream temperature was 31 degrees Celsius, and the maximum temperature
differential between the upstream and downstream samples was 3.3 degrees Celsius on August 3, 2016— this
differential was greater than the standard of 2.8 degrees Celsius (15A NCAC 02b .0211 (18)). It was a one-time
situation and based on the t-test was concluded that there is no statistically significant difference between the
upstream and downstream temperatures.
Hardness: Effluent hardness and instream hardness sampling, upstream of the discharge, are being sampled at
a quarterly monitoring frequency following the 2016 Dissolved Metal Standards in order to calculate permit
limitations for the seven metals that have hardness -dependent equations (Cd, Cr, Cu, Pb, Ni, Ag, and Zn). See
below the effluent and upstream data summary for hardness data from the analyzed period, May 2016 - March
2021.
Figure 2. Average, maximum, and minimum upstream and effluent hardness data summary
60.0
50.0
40.0
30.0
20.0
10.0
0.0
• Upstream
• Effluent
Average
25.3
42.1
Hardness, mg/I
Max
46.0
50.0
Min
16.0
32.0
With this permit renewal package, TRU requested to reduce instream monitoring to once per week; however,
per 15A NCAC 02B .0500 upstream and downstream monitoring in Water Quality -limited waters is to be
conducted 3/week during June, July, August, and September, and 1/week during the rest of the year, as specified
in the current permit. No changes are proposed for instream monitoring frequency.
The Division maintains two ambient monitoring stations in the South Fork Catawba River. One station is at SR
7 near McAdenville upstream of Eagle Road WWTP (downstream of the Long Creek WWTP) and the other
station is downstream of the Eagle Road WWTP at SR 273.
Table 5. Ambient Monitoring Stations South Fork Catawba River (SFCR)
Station ID
Location
Parameters Monitored
Collection Dates
C650000
SFCR at SR 7 near
McAdenville
Ammonia, Nitrate & Nitrite, TKN,
TP
2017 through 2019
C700000
SFCR at SR 2524
(Armstrong Rd)
Ammonia, Nitrate & Nitrite, TKN,
TP
2017 through 2019
Page 5 of 19

Table 6. Ambient Monitoring Stations C650000 and C700000 Data Summary from January 2017 to June 2019
Parameter
C650000
C700000
Ammonia, mg/1
Average
0.045
0.044
Maximum
0.22
0.13
Min
0.02
0.02
Nitrate & Nitrite, mg/1
Average
0.84
0.45
Maximum
1.4
0.76
Min
0.58
0.13
TKN, mg/1
Average
0.53
0.45
Maximum
1.5
0.98
Min
0.28
0.28
TP, mg/1
Average
0.15
0.07
Maximum
0.48
0.26
Min
0.07
0.03
Is this Facility a member of a Monitoring Coalition with waived instream monitoring (Y/N): NO
Name of Monitoring Coalition: NA
5. Compliance Summary
From June 2016 to April 2021, the Facility received one notice of violation (NOV) for failing to reach the
daily minimum (Dmin) for pH on June 23, 2017. The MRO representative, Ori Tuvia, is working with the
Facility to monitor the Facility's compliance performance.
Summary of the compliance record with aquatic toxicity test limits and any second species test results (past 5
years):
The Facility passed seventeen of seventeen quarterly chronic toxicity tests from March 2017 to March 2021
and complied with all four 2nd species WET tests (6/2018, 9/2018, 12/2018, and 3/2019).
Summary of the results from the most recent compliance inspection:
The last facility inspection conducted in February 2020 reported that both secondary clarifiers were operational;
however, only one was in operation due to low influent flows. Also, the Region noted that the Facility should
continue to investigate a plan to prevent floodwater from the river from backing through the effluent pipe into
the chlorine contact basins and potentially the secondary clarifiers at the plant.
6. Water Quality -Based Effluent Limitations (WQBELs)
6.1 Dilution and Mixing Zones
In accordance with 15A NCAC 2B.0206, the following stream flows are used for dilution considerations for
development of WQBELs: 1 Q 10 streamflow (acute Aquatic Life); 7Q10 streamflow (chronic Aquatic Life;
non -carcinogen HH); 30Q2 streamflow (aesthetics); annual average flow (carcinogen, HH).
If applicable, describe any other dilution factors considered (e.g., based on CORMIX model results): NA
If applicable, describe any mixing zones established in accordance with 15A NCAC 2B.0204(b): NA
Stream flow values were extracted from the previous Fact sheet (2002-2016).
Page 6 of 19

6.2 Oxygen -Consuming Waste Limitations
Limitations for oxygen -consuming waste (e.g., BOD) are generally based on water quality modeling to ensure
protection of the instream dissolved oxygen (DO) water quality standard. Secondary TBEL limits (e.g.,
BOD= 30 mg/1 for Municipals) may be appropriate if deemed more stringent based on dilution and model
results.
If permit limits are more stringent than TBELs, describe how limits were developed:
The current permit sets BOD5 MA limit as 10.0 mg/L and the WA limit as 15.0 mg/L. The limits for BOD5 are
based on a 1994 QUAL2E modeling for the protection of the DO standard. The minimum DO value from May
2016 through March 2021 was 6.1 mg/1. See the DO effluent data trend from the last year in the figure below.
The draft Permit retains the existing BOD5 limits in this permit cycle, and a minimum DO limit is added, 5.0
mg/L —per 15A NCAC 02B .0211(6); class C waters apply to all waters of the State.
Figure 3. Effluent dissolved oxygen data summary from 2/2020 — 2/2021.
0
Feb-20
Apr-20 May-20
DO, mg/I
40.
es
Jul-20
6.3 Ammonia and Total Residual Chlorine Limitations
Sep-20 Oct-20
Dec-20 Feb-21
Limitations for ammonia are based on protection of aquatic life utilizing an ammonia chronic criterion of 1.0
mg/1 (summer) and 1.8 mg/1 (winter). Acute ammonia limits are derived from chronic criteria, utilizing a
multiplication factor of 3 for Municipals and a multiplication factor of 5 for Non -Municipals.
Limitations for Total Residual Chlorine (TRC) are based on the NC water quality standard for protection of
aquatic life (17 ug/1) and capped at 28 ug/1 (acute impacts). Due to analytical issues, all TRC values reported
below 50 ug/1 are considered compliant with their permit limit.
Describe any proposed changes to ammonia and/or TRC limits for this permit renewal:
Ammonia: There are no proposed changes for ammonia. The current permit sets the ammonia MA limit as 4.0
mg/1 and WA limit as 12.0 mg/1 based on a calibrated QUAL2E model in 1994. The limits were not exceeded
in the evaluated period, and none of the ammonia results from the evaluated period exceeded 35 mg/1.
Page 7 of 19

TRC: The Facility uses chlorination as its primary disinfection. Clarified effluent is disinfected in a chlorine
contact basin where a sodium hypochlorite solution is introduced. Sodium bisulfite is used for dechlorination.
The current permit limits TRC at 28 ug/L as a daily maximum. Though several reported TRC values exceeded
the 28 ug/L daily maximum limit, the Facility is considered compliant with its permit since all reported values
were less than 50 ug/L. The maximum TRC value reported was 49 ug/L. The TRC limit has been reviewed in
the attached WLA and has been found to be protective. No changes are proposed for TRC.
6.4 Reasonable Potential Analysis (RPA) for Toxicants
The need for toxicant limits is based upon a demonstration of reasonable potential to exceed water quality
standards, a statistical evaluation that is conducted during every permit renewal utilizing the most recent effluent
data for each outfall. The RPA is conducted in accordance with 40 CFR 122.44 (d) (i). The NC RPA procedure
utilizes the following: 1) 95% Confidence Level/95% Probability; 2) assumption of zero background; 3) use of
1/2 detection limit for "less than" values; and 4) stream flows used for dilution consideration based on 15A
NCAC 2B.0206. Effective April 6, 2016, NC began implementation of dissolved metals criteria in the RPA
process in accordance with guidance titled NPDES Implementation of Instream Dissolved Metals Standards,
dated June 10, 2016.
The RPAs were conducted for permitted flows of 4.0 MGD with a 7Q10S of 125 cubic feet per second (cfs)
and specific hardness values. The answers below are based on the RPA.
RPAs were conducted on effluent toxicant data collected in the Permittee's 2016 to 2018 effluent pollutant
scans and DMRs. Pollutants of concern included toxicants with positive detections and associated water quality
standards/criteria. The data set was limited for arsenic, beryllium, cadmium, chromium total, copper, cyanide,
lead, mercury, molybdenum, nickel, selenium, silver, and zinc. Based on this analysis, the following permitting
actions are proposed for this permit:
• Effluent Limit with Monitoring. The following parameters will receive a water quality -based effluent
limit (WQBEL) since they demonstrated a reasonable potential to exceed applicable water quality
standards/criteria: NA
• Monitoring Only. The following parameters will receive a monitor -only requirement since they did
not demonstrate reasonable potential to exceed applicable water quality standards/criteria, but the
maximum predicted concentration was >50% of the allowable concentration: NA
• No Limit or Monitoring: The following parameters will not receive a limit or monitoring, since they
did not demonstrate reasonable potential to exceed applicable water quality standards/criteria, and the
maximum predicted concentration was <50% of the allowable concentration: Arsenic, beryllium,
cadmium, chromium, copper, cyanide, lead, molybdenum, nickel, selenium, zinc and total phenolic
compounds.
These compounds will be monitored in the pretreatment program during this permit cycle: None.
Pretreatment program is currently inactive.
• POTW Effluent Pollutant Scan Review: Three effluent pollutant scans were evaluated for additional
pollutants of concern.
o The following parameter(s) will receive a water quality -based effluent limit (WQBEL) with
monitoring since as part of a limited data set, two samples exceeded the allowable discharge
concentration: NA
o The following parameter(s) will receive a monitor -only requirement, since as part of a limited
data set, one sample exceeded the allowable discharge concentration: NA
RPA results, as well as a copy of the Dissolved Metals Implementation Fact Sheet for freshwater, are included
as attachments of this Fact Sheet.
Page 8 of 19

6.5 Toxicity Testing Limitations
Permit limits and monitoring requirements for Whole Effluent Toxicity (WET) have been established in
accordance with Division guidance (per WET Memo, 8/2/1999). Per WET guidance, all NPDES permits issued
to Major facilities or any facility discharging "complex" wastewater (contains anything other than domestic
waste) will contain appropriate WET limits and monitoring requirements, with several exceptions. The State
has received prior EPA approval to use an Alternative WET Test Procedure in NPDES permits, using single
concentration screening tests, with multiple dilution follow-up upon a test failure.
Describe proposed toxicity test requirement: This is a Major Publicly Owned Treatment Work (POTW), and a
chronic WET limit will continue to be required on a quarterly frequency at Outfall 001 at 4.7% at 4.0 MGD
using Ceriodaphnia dubia. Per 40 CFR 122.21(j)(5)(v), four second species will continue to be required as well.
6.6 Mercury Statewide Total Maximum Daily Load (TMDL) Evaluation
There is a statewide TMDL for mercury approved by EPA in 2012. The TMDL target was to comply with
EPA's mercury fish tissue criteria (0.3 mg/kg) for human health protection. The TMDL established a wasteload
allocation for point sources of 37 kg/year (81 lb/year) and is applicable to municipals and industrial facilities
with known mercury discharges. Given the small contribution of mercury from point sources (-2% of total
load), the TMDL emphasizes mercury minimization plans (MMPs) for point source control. Municipal
facilities > 2 MGD and discharging multiple quantifiable levels of mercury (>1 ng/1) received an MMP
requirement. Industrials are evaluated on a case -by -case basis, depending if mercury is a pollutant of concern.
Effluent limits may also be added if annual average effluent concentrations exceed the WQBEL value (based
on the NC WQS of 12 ng/1) and/or if any individual value exceeds a TBEL value of 47 ng/1
A mercury evaluation was conducted in accordance with the Permitting Guidance developed for the
implementation of the statewide Mercury TMDL to determine the need for a limit. The Facility implemented
an MMP in September 2017.
Below find summaries of compliance mercury data from 2017 to 2021. Based on the dataset, the water quality -
based effluent limitation (WQBEL) for mercury is 253.9 ng/1, and the technology -based effluent limit (TBEL)
is 47 ng/l.
Table 7. Mercury Effluent Data Summary and Evaluation
2017
2018
2019
# of Samples
1
1
1
Mercury Annual Average (ng/1)
0.5
1.6
1.2
Mercury Annual Max (ng/1)
0.50
1.62
1.16
TBEL, ng/L
47
WQBEL, ng/L
253.9
Describe proposed permit actions based on mercury evaluation: Mercury evaluation results used 1631E. No
annual average mercury concentration exceeded the WQBEL, and no individual mercury sample exceeded the
TBEL. The maximum value reported in this period was 1.62 ng/1. No mercury limit is required, and the mercury
minimization plan (MMP) will continue to be required in this permit cycle because multiple quantifiable levels
of mercury were >1 ng/1.
Page 9 of 19

6.7 Other TMDL/Nutrient Management Strategy Considerations
If applicable, describe any other TMDLs/Nutrient Management Strategies and their implementation within
this permit:
Lake Wylie TMDL
The Facility is subject to the Lake Wylie Nutrient TMDL and Management Strategy, which addresses eutrophic
conditions and chlorophyll -a water quality violations in the North Carolina portion of Lake Wylie and its
tributaries. The TMDL was developed in 1995 and approved by the EPA in 1998. The Strategy set TN and TP
load allocations for the lake and each major tributary. It then set individual mass load allocations (and the
equivalent concentrations) for existing large WWTPs and provided a process to allow for new/expanding
discharges. In the year 2000, the Division included permit limits of 6.0 mg/L (summer only) for Total Nitrogen
(TN) and 1.0 mg/L (year-round) for Total Phosphorus (TP) in the affected permits. Technology -based TN and
TP allowances for the existing industries (Clariant Corporation, NC0004375; Pharr Yarns, NC0004812; and
Kings Mountain Venture #1, NC0005274) were set based on BAT determinations prepared by each Facility.
(For the purposes of the following explanation, "allocation" means a water -quality -based cap on the amount of
nutrients that a permittee can potentially discharge, as established in a TMDL, applicable rule, or other
mechanism. On the other hand, "allowance" means a technology -based cap, such as through a BAT
determination.)
In 2013, Clariant sold most of its TN and TP allocations to the City of Charlotte for a planned wastewater
facility. Subsequently, other permittees expressed interest in transferring allocations ("trading"). In order to be
transferred between facilities, allocations must be expressed as mass loads. In response to the increased interest,
the Division calculated the mass load allocations for the facilities subject to the TMDL. In addition to the
TMDL's summer limits for TN and year-round limits for TP, it established new winter allocations and limits
for TN, equivalent to 12 mg/L TN.
The Division now implements nutrient controls in Lake Wylie using the following approach:
• The distribution of nutrient allocations — and any transfer of allocations — must be consistent with the
approved Lake Wylie TMDL.
a. The point source allocations assigned in the TMDL to the lake and its tributaries are valid
only in the original study area and cannot be transferred outside that area except through
modification of the TMDL and the approval of EPA Region 4.
b. Similarly, the tributary allocations identified in the TMDL are only valid within the assigned
subwatersheds and cannot be transferred elsewhere without EPA approval.
• Within each subwatershed, transfers and other changes in allocations cannot result in exceedance of the
tributary allocations in the TMDL. If additional industrial facilities request allocations based on BAT
determinations (none are foreseen at this time), the Division will consider the request with Region 4.
• Only those allocations that were identified in the TMDL (WWTPs) and approved allowances
(industries with approved BAT determinations) are valid. Facilities within the Lake Wylie study area
cannot receive credit for connecting other WWTPs located within or outside of the study area.
• No transfer of allocation will be incorporated into NPDES permits until the Division is satisfied that
the transfer will not result in localized impacts ("hot spots").
• TN allocations and limits will be implemented as follows:
Page 10 of 19

a. Summer mass TN allocations and limits for all affected dischargers will be set based on the
summer daily loads in the TMDL;
b. Winter allocations and limits will be based on 12 mg/L or other approved BAT
determinations;
c. Summer and winter mass TN allocations and limits for affected industries will be based on a
proportional split of the annual values, that is, 214/365 of the annual allowance for summer
and 151/365 for winter.
• TP allocations and limits will be implemented as annual mass values based on daily loads specified on
the TMDL or an approved BAT determination.
Applicable Nutrient Limits; Performance.
In its 2013 renewal application, Gastonia requested "bubble" limits for TN and TP for its Long Creek facility
(NC0020184) and its Eagle Road WWTP (NC0006033). The revised limits were included when the permits
were renewed in 2017. In both permits, per the Permittee's request, the monthly average TP limit of 1.0 mg/L
was replaced with an annual TP Load limit, and summer and winter TN Load limits (lb/season) were added.
With the 2017 permit renewal, Gastonia requested to add the loads from the following decommissioned
facilities: Ranlo, High Shoals, McAdenville, and Pharr Yarns. The towns of Ranlo, High Shoals, and Stanley
were connected to the Long Creek Facility but were not included in the TMDL as they were minor facilities.
As such, they did not have allocations in the approved TMDL implicit or explicit.
The individual allocations and combined limits at Outfall CO1 and the actual discharge loads for 2015-2020 are
as follows:
Table 8. Summary of Performance - Nutrients, 2015-2020 [Eagle Road WWTP (NC0006033) & Long Creek
WWTP (NC0020184)]
Facility
Period
2015
2016
2017
2018
2019
2020
2017
Alloc'n/Limit
Long Creek
Summer TN load, lb/summer
32,536
40,233
48,080
62,078
61,615
74,732
171,337
Eagle Road
Summer TN load, lb/summer
31,598
30,499
29,987
29,771
35,272
37,973
42,834
Combined TN Discharge,
lb/summer
64,134
70,732
78,067
91,849
96,887
112,705
214,171
Long Creek
Winter TN load, lb/winter
75,322
88,536
72,703
75,596
66,444
67,769
241,793
Eagle Road
Winter TN load, lb/winter
20,845
21,662
21,749
21,859
26,406
32,649
60,448
Combined TN Discharge,
lb/winter
96,167
110,198
94,452
97,455
92,850
100,418
302,241
Long Creek
Annual TP load, lb/yr
5,515
3,774
5,968
13,706
6,629
9,996
48,706
Eagle Road
Annual TP load, lb/yr
1,112
990
926
1,602
2,398
3,784
12,176
Combined TP Discharge,
lb/year
6,627
4,764
6,894
15,308
9,027
13,780
60,882
Page 11 of 19

Figure 4. Eagle Road's seasonal Effluent TN load data summary from 2015 to 2020.
40,000
35,000
30,000
25,000
20,000
15,000
10,000
5,000
0
Eagle Road WWTP - Seasonal TN load, lb/season
2015 2016 2017 2018 2019 2020
- Summer TN load, lb/summer
- Winter TN load, lb/winter
Figure 5. Eagle Road's annual Effluent TP data summary from 2015 to 2020.
4000
3500
3000
2500
2000
1500
1000
500
0
2015
Eagle Road WWTP - Annual TP load, Ib/yr
2016
2017
2018
2019
0
Eagle Road WWTP - TP(as P) - Concentration, mg/L
>, — a > C T — a > C > > C > — Q > C
m 0ra mZ Zra 2 2▪ Z Z
2016
2017
2018
2019
2020 2021
Page 12 of 19

Changes in Nutrient Allocations/ Allowances.
In 2017, Pharr Yarns was an industrial facility with a discharge of domestic and industrial wastewater not
connected to the Long Creek Facility, discharging directly to the South Fork Catawba River. In January 1, 2021,
the Pharr Yarns permit (NC0004812) was rescinded, and with this permit renewal, Gastonia requested the
inclusion of Pharr Yarns' nutrient allocation in the permit for the Eagle Road WWTP. The Division is adding
the nutrient allocation previously activated for Pharr Yarns (8,031 lb/season (TN Summer); 5,667 lb/season
(TN Winter); and 1,522 lb/season (annual TP)).
For the purpose of setting nutrient effluent limitations, the Long Creek and Eagle Road allocations continue to
be combined and are being modified to reflect increases in the Eagle Road allocations resulting from its
connection with the Pharr Yarns facility. The revised combined allocations and "bubble" limits for Outfall C01
are as follows:
Table 9.2021 Nutrient Allocations for Eagle Road WWTP and Long Creek WWTP
Permit
Facility
Total Nitrogen
Summer
(lb/season) 1,3
Total Nitrogen
Winter
(lb/season) 1,3
Total Phosphorus
Annual
(Ib/yr) z,3
NC0020184
Long Creek WWTP
171,337
241,793
48,706
NC0006033
Eagle Road WWTP
42,834
(effective through
60,448
(previously eff.
12,176
(effective through
10/31/2021)
through 3/31/2021)
12/31/2021)
Combined Load Limitations
214,171
(effective through
302,242
(previously eff.
60,882
(effective through
10/31/2021)
through 3/31/2021)
12/31/2021)
NC0006033
Eagle Road WWTP4
50,866
(revised eff.
66,115
revised
13,698
(eff. 1/1/2022)
4/1/2022
eff. 11/1/2021)
Combined Load Limitations4
222,203
(revised eff.
307,908
revised
62,404
(eff. 1/1/2022)
4/1/2022
eff. 11/1/2021)
Footnotes:
1. In accordance with the 1995 Lake Wylie TMDL, summer values apply April 1 - October 31, and winter
values apply November 1- March 31.
2. Total Phosphorus values apply for the calendar year; January 1 to December 31.
3. All values are displayed to the nearest pound. The Combined Load Limitations may not equal the
apparent sum due to the effects of rounding the individual values.
4. Limitations include the addition of Pharr Yarns allocations (8,031 lb/season (TN Summer); 5,667
lb/season (TN Winter); and 1,5221b/season (annual TP))
Allowances Held in Reserve. On December 27, 2017, the City of Gastonia entered into a contract with Lowell
Investments I, LLC (NC0005274; originally owned by Crompton and Knowles, later by Kings Mountain
Venture #1) for the purchase of its TN and TP allowances. Per Contract, Lowell Investments, whose permit is
now rescinded, sold its nitrogen and phosphorus allowances to the City "for the sole purpose of having the Total
Allocation held in reserve under Buyer's NPDES permit," and the City has the exclusive option to activate
those allocations for its own discharge in return for a final payment to Lowell Investments. Gastonia can execute
its option and acquire the allowances for a period of up to 15 years (with allowable extensions), such as for a
Page 13 of 19

future expansion. Until that time, at least, the allocations for the Eagle Road facility are not affected by this
transaction.
The TMDL does not address transfers ("trades"), and the Strategy is not implemented through rule. However,
other nutrient strategies include provisions that are relevant and, in the Division's best professional judgment,
can be applied here. For instance, in other river basins or watersheds, facilities cannot purchase allocation to
increase their original limits until those facilities are expanded; and, at that time, the increased nutrient load
limits (its "active" allocations) cannot exceed the equivalent of the new permitted flow and specified treatment
performance standards, given as annual average concentrations. Any allocations in excess of this amount are
held in reserve until they are eligible for use.
6.8 Other WQBEL Considerations
If applicable, describe any other parameters of concern evaluated for WQBELs: NA.
If applicable, describe any special actions (HQW or ORW) this receiving stream and classification shall
comply with in order to protect the designated waterbody: NA.
If applicable, describe any compliance schedules proposed for this permit renewal in accordance with 15A
NCAC 2H.0107(c) (2) (B), 40CFR 122.47, and EPA May 2007 Memo: NA.
If applicable, describe any water quality standards variances proposed in accordance with NCGS 143-
215.3(e) and 15A NCAC 2B.0226 for this permit renewal: NA
7. Technology -Based Effluent Limitations (TBELs)
Municipals (if not applicable, delete and skip to Industrials)
Are concentration limits in the permit at least as stringent as secondary treatment requirements (30 mg/1
BOD5/TSS for Monthly Average, and 45 mg/l for BOD5/TSS for Weekly Average). YES
If NO, provide a justification for alternative limitations (e.g., waste stabilization pond). NA
Are 85% removal requirements for BOD5/TSS included in the permit? YES
If NO, provide a justification (e.g., waste stabilization pond). NA
8. Antidegradation Review (New/Expanding Discharge)
The objective of an antidegradation review is to ensure that a new or increased pollutant loading will not
degrade water quality. Permitting actions for new or expanding discharges require an antidegradation review
in accordance with 15A NCAC 2B.0201. Each applicant for a new/expanding NPDES permit must document
an effort to consider non -discharge alternatives per 15A NCAC 2H.0105( c)(2). In all cases, existing instream
water uses and the level of water quality necessary to protect the existing use is maintained and protected.
If applicable, describe the results of the antidegradation review, including the Engineering Alternatives
Analysis (EAA) and any water quality modeling results: NA
9. Antibacksliding Review
Sections 402(o)(2) and 303(d)(4) of the CWA and federal regulations at 40 CFR 122.44(1) prohibit
backsliding of effluent limitations in NPDES permits. These provisions require effluent limitations in a
reissued permit to be as stringent as those in the previous permit, with some exceptions where limitations may
be relaxed (e.g., based on new information, increases in production may warrant less stringent TBEL limits,
or WQBELs may be less stringent based on updated RPA or dilution).
Page 14 of 19

Are any effluent limitations less stringent than previous permit (YES/NO): NO. On the expiration of the
permit, there were not TP and TN concentration limits in effect.
If YES, confirm that antibacksliding provisions are not violated: NA
10. Monitoring Frequency Requirements
Monitoring frequencies for NPDES permitting are established in accordance with the following regulations
and guidance: 1) State Regulation for Surface Water Monitoring, 15A NCAC 2B.0500; 2) NPDES Guidance,
Monitoring Frequency for Toxic Substances (7/15/2010 Memo); 3) NPDES Guidance, Reduced Monitoring
Frequencies for Facilities with Superior Compliance (10/22/2012 Memo); 4) Best Professional Judgement
(BPJ). Per US EPA (Interim Guidance, 1996), monitoring requirements are not considered effluent
limitations under Section 402(o) of the Clean Water Act, and therefore anti -backsliding prohibitions would
not be triggered by reductions in monitoring frequencies.
TRU requested that the required monitoring frequency for total suspended solids (TSS), ammonia, and fecal
coliform be kept at twice per week. Upon evaluating the monitoring data, the Facility continued to meet the
approval criteria for monitoring reduction for BOD5, TSS, ammonia, and fecal coliform (based on the DWR
Guidance Regarding the Reduction of Monitoring Frequencies in NPDES Permits for Exceptionally
Performing Facilities); therefore, the Facility's monitoring frequency for BOD5, TSS, ammonia, and fecal
coliform will remain as twice per week.
For instream monitoring, refer to Section 4.
11. Electronic Reporting Requirements
The US EPA NPDES Electronic Reporting Rule was finalized on December 21, 2015. Effective December
21, 2016, NPDES regulated facilities are required to submit Discharge Monitoring Reports (DMRs)
electronically. While NPDES regulated facilities would initially be required to submit additional NPDES
reports electronically effective December 21, 2020, EPA extended this deadline from December 21, 2020, to
December 21, 2025. The current compliance date, effective January 4, 2021, was extended as a final
regulation change published in the November 2, 2020, Federal Register. This permit contains the
requirements for electronic reporting, consistent with Federal requirements.
12.Summary of Proposed Permitting Actions
Table 10. Current Permit Conditions and Proposed Changes for 4.0 MGD
Parameter
Current Permit Limits and
Monitoring Frequency
Proposed Change
Basis for Condition/Change
Flow
MA 4.0 MGD
Continuous monitoring
No changes
15A NCAC 2B .0505
The average flow for the past five years
was 0.80 MGD
Total Monthly Flow
Monthly monitoring
No changes
Needed to calculate nutrient loads
BOD5
For 4.0 MGD
MA 10.0 mg/I
WA 15.0 mg/I
Monitor 2/week
No changes
Water quality based on 1994 QUAL2E
modeling for protection of the DO
standard
Effluent guideline (EGL) mass limit for
BOD5 (334 Ibs/day) was converted to an
equivalent concentration -based limit
(10 mg/I MA, 15 mg/I WA).
Page 15 of 19

TSS
For 4.0 MGD
MA 30 mg/I
WA 45 mg/I
Monitor 2/week
No changes
TBEL. Secondary treatment
standards/40 CFR 133 / 15A NCAC 2B
.0406.
NH3-N
For 4.0 MGD
MA 4 mg/I
WA 12 mg/I
Monitor 2/week
No changes
Water quality based on 1994 QUAL2E
modeling for protection of the DO
standard
DO
Monitor and report
instream at a variable**
frequency
Monitor effluent daily
Added minimum DO
effluent limit - not less
than 5.0 mg/I.
WQBEL. State WQ standard, 15A NCAC
2B .0200, 15A NCAC 2B.0500
15A NCAC 02B .0211(6); class C waters
apply to all waters of the state
Fecal conform
(Geometric Mean)
MA 200 /100m1
WA 400 /100m1
Monitor 2/week
No changes
WQBEL. State WQ standard, 15A NCAC
2B .0200.
Temperature
Monitor effluent daily
Monitor and report
instream at a variable**
frequency
No changes
15A NCAC 2B.0200 and 15A NCAC
2B.0500
Conductivity
None
Monitor and report at
effluent daily and
instream at a
variable** frequency
The facility has industrial dischargers
15A NCAC 2B.0500
Turbidity
None
Monitor and report at
a quarterly frequency
The receiving stream, South Fork
Catawba River, was recently listed in
the NC draft 2020 303(d) list for
turbidity
Class C waters apply to all waters —
15A NCAC 02B .0211(21)
pH
6 — 9 SU.
Monitor daily
No changes
WQBEL. State W.Q. standard, 15A
NCAC 2B .0200
TRC
DM 28.0 µg/I
Monitor daily
No changes
WQBEL. State WQ standard, 15A NCAC
2B .0200. The Division considers all
effluent TRC values reported below 50
ug/I to be in compliance with the
permit
Total Hardness
Quarterly monitoring
upstream and in effluent
No changes
Hardness -dependent dissolved metals
water quality standards approved in
2016
TKN
Monitor and report
weekly
No changes
Lake Wylie TMDL permitting strategy
NO3-N + NO2-N
Monitor and report
weekly
No changes
Lake Wylie TMDL permitting strategy
Page 16 of 19

Total Nitrogen (TN)
Monitor and report
weekly
No changes
Lake Wylie TMDL permitting strategy
sets concentration limit of 6.0 mg/I
(Summer) and 12.0 mg/I (Winter) for
TN. In previous permit cycles, TRU
requested the removal of the TN
concentration limit
TN Load
Monitor and report
monthly and seasonally
Summer combined
allocation for Long Creek
and Eagle Road:
214,171 Ib/season
Winter combined
allocation for Long Creek
and Eagle Road:
302,242 Ib/season
Monitor and report
monthly and seasonally
Summer combined
allocation for Long
Creek and Eagle Road:
222,203 Ib/season
Winter combined
allocation for Long
Creek and Eagle Road:
307,908 Ib/season
See table 9 for detailed
effective dates.
Lake Wylie TMDL permitting strategy.
"Bubble Limits' for Long Creek and
Eagle Road
Total Phosphorus (TP)
MA: 1 mg/I (through
12/31/2017)
Monitor and report
weekly
Maintain existing
weekly monitoring and
reporting
Lake Wylie TMDL permitting strategy
set a concentration limit of 1.0 mg/I for
TP. Per the permittee request, the TP
concentration limit was removed in the
previous permit cycle. The Division
reviewed the current data projected for
the full design flow and has decided not
to reinstate the concentration limit.
Over the past several years, the Lake
Wylie permittees have focused entirely
on mass limits, which are acceptable
under the TMDL.
TP Load
Monitor and report
monthly and seasonally
(effective 1/1/18)
Annual combined
allocation for Long Creek
and Eagle Road: 60,882
Ib/yr
Monitor and report
monthly and seasonally
Annual combined
allocation for Long
Creek and Eagle Road:
62,404 Ib/yr
See table 9 for detailed
effective dates.
Lake Wylie TMDL permitting strategy.
"Bubble Limits" for Long Creek and
Eagle Road.
Toxicity Test
Chronic limit, 4.7% at 4.0
MGD
No changes
WQBEL. No toxics in toxic amounts.
15A NCAC 2B.0200 and 15A NCAC
2B.0500
Effluent Pollutant
Scan
Three times per permit
cycle for 4.0 MGD
Next scans must be
performed in each of
40 CFR parts 423 and 122
1 Combined allocation for multiple WWTPs
Page 17 of 19

the following years:
2024, 2025, and 2026.
Mercury Minimization
Plan (MMP)
MMP
for 4.0 MGD
No changes
Consistent with EPA approved 2012
Statewide Mercury TMDL
Implementation.
Electronic Reporting
Electronic reporting
special condition
for 4.0 MGD
Added language for
new electronic
reporting deadline
December 21, 2025
In accordance with EPA Electronic
Reporting Rule 2015 and Rule -Phase 2
Extension
* MA - Monthly Average, WA — Weekly Average, DM — Daily Max.
** Variable monitoring frequency is defined as follows: samples collected three times per week during June 1 through September 30
and once per week October 1 through May 31.
13. Public Notice Schedule
Permit to Public Notice: September 7, 2021
Per 15A NCAC 2H .0109 & .0111, The Division will receive comments for a period of 30 days following the
publication date of the public notice. Any request for a public hearing shall be submitted to the Director
within the 30 days comment period indicating the interest of the party filing such request and the reasons why
a hearing is warranted.
If you have any questions regarding any of the above information or on the attached permit, please contact
Diana Yitbarek at [phone] or via email at [e-mail]
14. Fact Sheet Addendum (if applicable)
Were there any changes made since the Draft Permit was public noticed (Yes/No): Yes
If Yes, list changes and their basis below:
• The Supplement to Permit Cover Sheet of the NPDES permit has been updated to reflect the correct
size of the following facility components Aeration basin: 6.3 MG; Clarifiers: 690,000 gallons each;
Chlorine contact basin: 94,000 gallons.
• Part I Section A. (8.) 1 Reporting Requirements of the NPDES permit has been updated to correct
language and include the following:
"The Permittee shall report discharge monitoring data electronically using the NC DWR's Electronic
Discharge Monitoring Report (eDMR) internet application.
Monitoring results obtained during the previous month(s) shall be summarized for each month and
submitted monthly electronically using eDMR. The eDMR system allows permitted facilities to enter
monitoring data and submit DMRs electronically using the internet. The eDMR system may be
accessed at: https://deq.nc.gov/about/divisions/water-resources/edmr
If a permittee is unable to use the eDMR system due to a demonstrated hardship or due to the facility
being physically located in an area where less than 10 percent of the households have broadband
access, then a temporary waiver from the NPDES electronic reporting requirements may be granted,
and discharge monitoring data may be submitted on paper DMR forms (MR 1, 1.1, 2, 3) or
alternative"
• The TP concentration limit was removed from the Part I Section A. (1.).
• Special Condition A. (7.) was modified to update the specific three years in which the Effluent
Pollutant Scan shall be performed (2024, 2025, and 2026).
Page 18 of 19

15. Fact Sheet Attachments (upon request):
1. RPA Sheets Summary for 4.0 MGD: input information, data analyzed, hardness dependent metals
table, and results summary
2. BOD and TSS Removal Rate calculations
3. NH3/TRC/Fecal Waste Load Allocation (WLA) Spreadsheet for 4.0 MGD
4. Mercury TMDL Calculations for 4.0 MGD
5. Toxicity Summary/WET testing
6. Instream data summary and ttest
7. Monitoring Report Violations Summary
8. Renewal Application Addendums
o Signed Effluent Pollutant Scans
o Addendum Form 2A
o June 2020 Industrial Waste Survey Report
o Nutrients Agreement — Lowell Investments
o Nutrients Agreement — Selkirk Realty (Former Pharr Yarns)
o 2020 Industrial Waste Survey (IWS)
9. Correspondence
10. NPDES Implementation of Instream Dissolved Metals Standards — Freshwater Standards
11. 2020 NC 303(d) List (one page)
12. Public Water Supply Memo
13. Affidavit
14. Public Comments and Responses
Page 19 of 19

Freshwater RPA - 95% Probability/95% Confidence Using Metal Translators
MAXIMUM DATA POINTS = 58
REQUIRED DATA ENTRY
Table 1. Project Information
Facility Name
WWTP/WTP Class
NPDES Permit
Outfall
Flow, Qw (MGD)
Receiving Stream
HUC Number
Stream Class
CHECK IF HQW OR ORW WQS
Eagle Road
IV
NC0006033
001
4.000
South Fork Catawba River
0305010206
W S-V
El Apply WS Hardness WQC
7Q10s (cfs)
7Q1Ow (cfs)
30Q2 (cfs)
QA (cfs)
1 Q10s (cfs)
125.000
230.00
309.00
810.00
I 101.87
Effluent Hardness
Upstream Hardness
Combined Hardness Chronic
Combined Hardness Acute
42.05 mg/L (Avg)
25.31 mg/L (Avg)
26.1 mg/L
26.27 mg/L
Note: 7Q10S, 7Q10W, 30Q2, and QA values were
taken from previous fact sheet. Limited dataset for
arsenic, beryllium, cadmium,chromium total, copper,
cyanide, lead, mercury, molybdenum, nickel,
selenium, silver, and zinc
Data Source(s)
CHECK TO APPLY MODEL
Table 2. Parameters of Concern
Par01
Par02
Par03
Par04
Par05
Par06
Par07
Par08
Par09
Par10
Par11
Par12
Par13
Par14
Par15
Par16
Par17
Par18
Par19
Par20
Par21
Par22
Par23
Par24
Name
WQS
Type Chronic Modifier
Acute
PQL Units
Arsenic
Aquactic Life
C
150
FW
340
ug/L
Arsenic
Human Health
Water Supply
C
10
HH/WS
N/A
ug/L
Beryllium
Aquatic Life
NC
6.5
FW
65
ug/L
Cadmium
Aquatic Life
NC
0.6095
FW
3.3832
ug/L
Chlorides
Water Supply
NC
250
WS
Chlorinated Phenolic Compounds
Water Supply
NC
1
A
ug/L
yTotal Phenolic Compounds
Aquatic Life
NC
300
A
ug/L
Chromium III
Aquatic Life
NC
121.9722
FW
942.6529
ug/L
Chromium VI
Aquatic Life
NC
11
FW
16
pg/L
Chromium, Total
Aquatic Life
NC
N/A
FW
N/A
pg/L
Copper
Aquatic Life
NC
8.1770
FW
10.9736
ug/L
Cyanide
Aquatic Life
NC
5
FW
22
10
ug/L
Fluoride
Aquatic Life
NC
1,800
FW
ug/L
Lead
Aquatic Life
NC
3.0882
FW
79.8274
ug/L
Mercury
Aquatic Life
NC
12
FW
0.5
ng/L
Molybdenum
Water Supply
NC
160
WS
ug/L
Nickel
Aquatic Life
NC
38.6171
FW
349.5921
pg/L
Nickel
Water Supply
NC
25.0000
WS
N/A
pg/L
Selenium
Aquatic Life
NC
5
FW
56
ug/L
Silver
Aquatic Life
NC
0.06
FW
0.3228
ug/L
Zinc
Aquatic Life
NC
131.4579
FW
131.1075
ug/L
Chloroform
Human Health
C
60
HH
pg/L
Chlorodibromomethane
Human Health
C
0.8
HH
pg/L
Dichlorobromomethane
Human Health
C
0.95
HH
pg/L
06033 RPA 4.0.xlsm, input
4/26/2021

Eagle Road
NC0006033
Qw (MGD) = 4.0000
1Q1OS (cfs) = 101.87
7Q10S (cfs) = 125.00
7Q10W (cfs) = 230.00
30Q2 (cfs) = 309.00
Avg. Stream Flow, QA (cfs) = 810.00
Receiving Stream: South Fork Catawba
Freshwater RPA - 95% Probability/95% Confidence Using Metal Translators
MAXIMUM DATA POINTS = 58
WWTP/WTP Class: IV
IWC% @ 1Q10S = 5.7370223
IWC% @ 7Q105 = 4.725609756
IWC% @ 7Q1OW = 2.624894157
IWC% @ 30Q2 = 1.967005076
IW%C @ QA = 0.759617741
Stream Class: WS-V
River HUC 0305010206
Outfall 001
Qw = 4 MGD
COMBINED HARDNESS (mu/El
Acute = 26.27 mg/L
Chronic = 26.1 mg/L
YOU HAVE DESIGNATED THIS RECEIVING
STREAM AS WATER SUPPLY
Effluent Hard: 0 value > 100 mg/L
Effluent Hard Avg = 42.05 mg/L
PARAMETER
TYPE
NC STANDARDS OR EPA CRITERIA
J
a
REASONABLE POTENTIAL RESULTS
RECOMMENDED ACTION
Applied
Chronic Standard Acutc
11 # Det. Max Pred Cw Allowable Cw
Arsenic
Arsenic
C
C
150 FW(7010s) 340
10 HH/WS(Qavg)
ug;L
ug/L
3 1
Note: n < 9
Limited data set
6.6
C.V. (default)
Acute (FW): 5,926.4
Chron(FW): _ 3,1_ 74.2 _ ________________
ic
No_value?AllowableCw_
Chronic (HH): 1,316.5
No value > Allowable Cw
_______
_ _ _ _ _ _ _ _ _ _ _ _
Limited dataset. Predicted Max < 50% of Allowable
Cw - No Monitoring required, other than pollutant
scan (PS)
Beryllium
NC
6.5 FW(7Q10s) 65
ug/L
3 0
Note: n < 9
Limited data set
1.50
C.V. (default)
NO DETECTS
Acute: 1,132.99
___ _ _______ _ ___
Chronic: 137.55
Max MDL = 1
_ _ _ _ _ _ _ _ _ _ _ _ _
All values in limited dataset reported non -detect < 1
ug/L. Predicted Max < 50% of Allowable Cw - No
Monitoring required, other than PS.
Cadmium
NC
0.6095 FW(7Q10s) 3.3832
ug/L
3 0
Note: n < 9
Limited data set
1.500
C.V. (default)
NO DETECTS
Acute: 58.971
-_ _ _ _ _ _ _ _
Chronic: 12.897
Max MDL = 1
_ _
All values in limited dataset reported non -detect
Predicted Max < 50% of Allowable Cw - No
Monitoring required, other than PS.
Total Phenolic Compounds
NC
300 A(30Q2)
ug/L
10 6
11.8
Acute: NO WQS
_ _ _ _ _ _ _ _ _ _ _ _ _
Chronic: 15,251.6
No value > Allowable Cw
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _
No RP, Predicted Max < 50% of Allowable Cw.
Predicted Max < 50% of Allowable Cw - No
Monitoring required, other than PS.
Chromium III
NC
121.9722 FW(7Q10s) 942.6529
µg/L
0 0
N/A
Acute: 16,431.0
-- _ _ _ ----_ _
Chronic: 2,581.1 -----------------------------
See Chromium, Total
Chromium VI
NC
11 FW(7Q10s) 16
µg/L
0 0
N/A
>_ 5 but < Cr VI Allowable
6.6
C.V. (default)samples
Acute: 278.9
___ _ _______ _____
Chronic: 232.8
_ _ _ _ _________________
See Chromium, Total
Chromium, Total
NC
µg/L
Tot Cr value(s)
3 1
Note: n < 9
Limited data set
Cw
Max reported value = 2.2
a: No monitoring required if all Total Chromium
are < 5 pg/L or Pred. max for Total Cr is <
allowable Cw for Cr VI.
Copper
NC
8.1770 FW(7Q10s) 10.9736
ug/L
3 3
Note: n < 9
Limited data set
15.60
Acute: 191.28
_ _ _ _ _ _ _ _ _
Chronic: 173.04
No value > Allowable Cw
_ _ _ _ _ _ -
Limited dataset. Predicted Max < 50% of Allowable
Cw - No Monitoring required, other than pollutant
scan (PS)
Cyanide
NC
5 FW(7Q10s) 22
10
ug/L
3 0
15.0
Acute: 383.5
Page 3 of 16
06033 RPA 4.0.xlsm, rpa
4/26/2021

Eagle Road
NC0006033
Freshwater RPA - 95% Probability/95% Confidence Using Metal Translators
Outfall 001
Qw = 4 MGD
Note: n < 9
Limited data set
C.V. (default)
NO DETECTS
Chronic: 105.8
Max MDL = 10
All values in limited dataset reported non -detect
Predicted Max < 50% of Allowable Cw - No
Monitoring required, other than PS.
Lead
NC
3.0882 FW(7Q10s) 79.8274
ug/L
3 0
Note: n < 9
Limited data set
1.500
C.V. (default)
NO DETECTS
Acute: 1,391.443
_ _ _ _ _ _ _ _ _ _ _ _ _ _
Chronic: 65.351
Max MDL = 1
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _
All values in limited dataset reported non -detect.
Predicted Max < 50% of Allowable Cw - No
Monitoring required, other than PS.
Mercury
NC
12 FW(7Q10s)
0.5
ng/L
3 2
Note: n < 9
Limited data set
4.9
C.V. (default)
Acute: NO WQS
___ _ _______ _____
Chronic: 253.9
No value > Allowable Cw
_ _ _ _ _ _ _ _ _ _ _ _
See section 6.6 Mercury Statewide Total Maximum
Daily Load (TMDL) Evaluation
Molybdenum
NC
160 WS(7Q10s)
ug/L
2 0
Note: n < 9
Limited data set
1.9
C.V. (default)
NO DETECTS
Acute: NO WQS
___ _ _____ _ _ _____________________________
Chronic: 3,385.8
Max MDL = 1
Nickel
Nickel
NC
NC
38.6171 FW(7Q10s) 349.5921
25.0000 WS(7Q10s)
µg/L
µg/L
3 3
Note: n < 9
Limited data set
7.2
C.V. (default)
Acute (FW): 6,093.6
Chro_ nic(F_W): ---817.2------------------------------
Allowable _ _ _
Novalue ?52
Chronic (WS): 9.0
No value > Allowable Cw
_ _ _ _ _ _ _ _ _ _ _ _ _ _
Limited dataset. Predicted Max < 50% of Allowable
Cw - No Monitoring required, other than pollutant
scan (PS)
Selenium
NC
5 FW(7Q10s) 56
ug/L
3 0
Note: n < 9
Limited data set
1.5
C.V. (default)
NO DETECTS
Acute: 976.1
___ _ _______ _______________________________
Chronic: 105.8
Max MDL = 1
All values reported non -detect < 1 ug/L. Predicted
Max < 50% of Allowable Cw - No Monitoring required
Silver
NC
0.06 FW(7Q10s) 0.3228
ug/L
3 0
Note: n < 9
Limited data set
1.500
C.V. (default)
NO DETECTS
Acute: 5.627
Chronic: 1.270
Max MDL = 1
All values reported non -detect < 1 ug/L. Predicted
Max > Allowable Cw - Add quarterly monitoring
Zinc
NC
131.4579 FW(7Q10s) 131.1075
ug/L
3 3
Note: n < 9
Limited data set
126.0
C.V. (default)
Acute: 2,285.3
_ _ _ _ _ _ _ _ _ _ _ _ _
Chronic: 2,781.8
No value > Allowable Cw
_ _ _ _ _ _ _ _ _ _ _ _ _ _
Limited dataset. Predicted Max < 50% of Allowable
Cw - No Monitoring required, other than PS
Chloroform
C
60 HH(Qavg)
µg/L
3 3
Note: n < 9
Limited data set
75.00000
C.V. (default)
Acute: NO WQS
_ _ _ _ _ _ _ _ _ _ _
Chronic: 7898.710
No value > Allowable Cw
_ _ _ _ _ _ _ _ _ _ _ _ _ _
Limited dataset. Predicted Max < 50% of Allowable
Cw - No Monitoring required, other than PS
Chlorodibromomethane
C
0.8 HH(Qavg)
µg/L
3 2
Note: n < 9
Limited data set
6.60000
C.V. (default)
Acute: NO WQS
___ _ _____ _ _ _____________________________
Chronic: 105.31613
No value > Allowable Cw
Limited dataset. Predicted Max < 50% of Allowable
Cw - No Monitoring required, other than PS
Dichlorobromomethane
C
0.95 HH(Qavg)
µg/L
3 3
21.00000
Acute: NO WQS
Page 4 of 16
06033 RPA 4.0.xlsm, rpa
4/26/2021

Eagle Road
NC0006033
Freshwater RPA - 95% Probability/95% Confidence Using Metal Translators
Note: n < 9
Limited data set
C.V. (default) Chronic: 125.06290
No value > Allowable Cw
Outfall 001
Qw=4MGD_
of Allowable
Limited dataset. Predicted Max < 50%
Cw - No Monitoring required, other than PS
Page 5 of 16
06033 RPA 4.0.xlsm, rpa
4/26/2021

REASONABLE POTENTIAL ANALYSIS
H1
Effluent Hardness
Date Data BDL=1/2DL Results
1 4/7/2017 34 34 Std Dev.
2 6/6/2017 44 44 Mean
3 7/7/2017 36 36 C.V.
4 10/6/2017 42 42 n
5 1/5/2018 32 32 10th Per value
6 4/6/2018 40 40 Average Value
7 7/6/2018 34 34 Max. Value
8 9/14/2018 35 35
9 10/5/2018 41 41
10 1/7/2019 45 45
11 3/7/2019 50 50
12 4/5/2019 50 50
13 7/5/2019 42 42
14 10/4/2019 50 50
15 1/3/2020 42 42
16 4/3/2020 46 46
17 7/10/2020 42 42
18 10/2/2020 44 44
19 1/15/2021 50 50
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
H2
Use "PASTE SPECIAL
Values" then "COPY"
. Maximum data
points = 58
5.8068
42.0526
0.1381
19
34.00 mg/L
42.05 mg/L
50.00 mg/L
Upstream Hardness
Use "PASTE SPECIAL
Values" then "COPY"
. Maximum data
points = 58
Date Data BDL=1/2DL Results
1 4/5/2017 30 30 Std Dev. 7.8547
2 7/7/2017 46 46 Mean 25.3125
3 10/6/2017 28 28 C.V. 0.3103
4 1/2/2018 22 22 n 16
5 4/6/2018 24 24 10th Per value 17.00 mg/L
6 7/6/2018 26 26 Average Value 25.31 mg/L
7 10/5/2018 25 25 Max. Value 46.00 mg/L
8 1/7/2019 16 16
9 4/5/2019 32 32
10 7/5/2019 24 24
11 10/4/2019 36 36
12 1/3/2020 16 16
13 4/3/2020 22 22
14 7/10/2020 20 20
15 10/2/2020 20 20
16 1/15/2021 18 18
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
-6-
06033 RPA 4.0.xlsm, data
4/26/2021

REASONABLE POTENTIAL ANALYSIS
Par01 & Par02
Arsenic
Date Data BDL=1/2DL Results
1 6/6/2017 2.2 2.2 Std Dev.
2 9/14/2018 < 1 0.5 Mean
3 3/7/2019 < 1 0.5 C.V. (default)
4 n
5
6 Mult Factor =
7 Max. Value
8 Max. Pred Cw
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
Use "PASTE SPECIAL
Values" then "COPY"
. Maximum data
points = 58
0.9815
1.0667
0.6000
3
3.00
2.2 ug/L
6.6 ug/L
-7-
06033 RPA 4.0.xlsm, data
4/26/2021

REASONABLE POTENTIAL ANALYSIS
Par03
Beryllium
Date Data BDL=1/2DL Results
1 6/6/2017 < 1 0.5 Std Dev.
2 9/14/2018 < 1 0.5 Mean
3 3/7/2019 < 1 0.5 C.V. (default)
4 n
5
6 Mult Factor =
7 Max. Value
8 Max. Pred Cw
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
Use "PASTE SPECIAL
Values" then "COPY"
. Maximum data
points = 58
Par04
Cadmium
0.0000
0.5000
0.6000
3
3.00
0.50 ug/L
1.50 ug/L
Date Data BDL=1/2DL Results
1 6/6/2017 < 1 0.5 Std Dev.
2 9/14/2018 < 0.5 0.25 Mean
3 3/7/2019 < 0.5 0.25 C.V. (default)
4 n
5
6 Mult Factor =
7 Max. Value
8 Max. Pred Cw
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
Use "PASTE SPECIAL
Values" then "COPY"
. Maximum data
points = 58
0.1443
0.3333
0.6000
3
3.00
0.500 ug/L
1.500 ug/L
-8-
06033 RPA 4.0.xlsm, data
4/26/2021

REASONABLE POTENTIAL ANALYSIS
Par07
Total Phenolic Compounds
Date Data BDL=1/2DL Results
1 5/5/2016 5.4 5.4 Std Dev.
2 6/9/2016 7.8 7.8 Mean
3 6/23/2016 6 6 C.V.
4 7/7/2016 6.6 6.6 n
5 8/3/2016 7.6 7.6
6 9/2/2016 6.2 6.2 Mult Factor =
7 10/6/2016 < 5 2.5 Max. Value
8 11/3/2016 7.1 7.1 Max. Pred Cw
9 12/1/2016 11
10 1/6/2017 < 5 2.5
11 2/2/2017 < 5 2.5
12 3/2/2017 < 5 2.5
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
Use "PASTE SPECIAL
Values" then "COPY"
. Maximum data
points = 58
2.2115
5.1545
0.4290
11
1.51
7.8 ug/L
11.8 ug/L
Par10
Chromium, Total
Date Data BDL=1/2DL Results
1 6/6/2017 2.20 2.2 Std Dev.
2 9/14/2018 < 1.00 0.5 Mean
3 3/7/2019 < 1.00 0.5 C.V. (default)
4 n
5
6 Mult Factor =
7 Max. Value
8 Max. Pred Cw
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
Use "PASTE SPECIAL
Values" then "COPY"
. Maximum data
points = 58
0.9815
1.0667
0.6000
3
3.00
2.2 pg/L
6.6 pg/L
-9-
06033 RPA 4.0.xlsm, data
4/26/2021

REASONABLE POTENTIAL ANALYSIS
Pall
Copper
Date Data BDL=1/2DL Results
1 6/6/2017 4.9 4.9 Std Dev.
2 9/14/2018 5.2 5.2 Mean
3 3/7/2019 3.2 3.2 C.V. (default)
4 n
5
6 Mult Factor =
7 Max. Value
8 Max. Pred Cw
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
Use "PASTE SPECIAL
Values" then "COPY"
. Maximum data
points = 58
Par12
Cyanide
1.0786
4.4333
0.6000
3
3.00
5.20 ug/L
15.60 ug/L
Date Data BDL=1/2DL Results
1 6/6/2017 < 10 5 Std Dev.
2 9/14/2018 < 10 5 Mean
3 3/7/2019 < 10 5 C.V. (default)
4 n
5
6 Mult Factor =
7 Max. Value
8 Max. Pred Cw
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
Use "PASTE SPECIAL
Values" then "COPY"
. Maximum data
points = 58
0.0000
5.00
0.6000
3
3.00
5.0 ug/L
15.0 ug/L
-10-
06033 RPA 4.0.xlsm, data
4/26/2021

REASONABLE POTENTIAL ANALYSIS
Par14
Lead
Date BDL=1/2DL Results
1 6/6/2017 < 1.00 0.5 Std Dev.
2 9/14/2018 < 1.00 0.5 Mean
3 3/7/2019 < 1.00 0.5 C.V. (default)
4 n
5
6 Mult Factor =
7 Max. Value
8 Max. Pred Cw
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
Par15
Use "PASTE SPECIAL
Values" then "COPY"
. Maximum data
points = 58
0.0000
0.5000
0.6000
3
3.00
0.500 ug/L
1.500 ug/L
Mercury
Date Data BDL=1/2DL Results
Use"PASTE SPECIAL
Values" then "COPY"
. Maximum data
points = 58
1 6/6/2017 < 1.00 0.5 Std Dev. 0.5630
2 9/14/2018 1.62 1.62 Mean 1.0933
3 3/7/2019 1.16 1.16 C.V. (default) 0.6000
4 n 3
5
6 Mult Factor = 3.00
7 Max. Value 1.6 ng/L
8 Max. Pred Cw 4.9 ng/L
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
-11-
06033 RPA 4.0.xlsm, data
4/26/2021

REASONABLE POTENTIAL ANALYSIS
Par16
Molybdenum
Date Data BDL=1/2DL Results
1 9/14/2018 < 1.00 0.5 Std Dev.
2 3/7/2019 < 1.00 0.5 Mean
3 C.V. (default)
4 n
5
6 Mult Factor =
7 Max. Value
8 Max. Pred Cw
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
Use "PASTE SPECIAL
Values" then "COPY"
. Maximum data
points = 58
Par17 & Par18
Nickel
0.0000
0.5000
0.6000
2
3.79
0.5 ug/L
1.9 ug/L
Date Data BDL=1/2DL Results
1 6/6/2017 2.00 2 Std Dev.
2 9/14/2018 2.40 2.4 Mean
3 3/7/2019 1.00 1 C.V. (default)
4 n
5
6 Mult Factor =
7 Max. Value
8 Max. Pred Cw
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
Use"PASTE
SPECIAL -Values"
then "COPY" .
Maximum data
points = 58
0.7211
1.8000
0.6000
3
3.00
2.4 pg/L
7.2 pg/L
-12-
06033 RPA 4.0.xlsm, data
4/26/2021

REASONABLE POTENTIAL ANALYSIS
Par19
Selenium
Date Data BDL=1/2DL Results
1 6/6/2017 < 1.00 0.5 Std Dev.
2 9/14/2018 < 1.00 0.5 Mean
3 3/7/2019 < 1.00 0.5 C.V. (default)
4 n
5
6 Mult Factor =
7 Max. Value
8 Max. Pred Cw
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
Use"PASTE
SPECIAL -Values
then "COPY" .
Maximum data
points = 58
Par20
Silver
0.0000
0.5000
0.6000
3
3.00
0.5 ug/L
1.5 ug/L
Date Data BDL=1/2DL Results
1 6/6/2017 < 1.00 0.5 Std Dev.
2 9/14/2018 < 1.00 0.5 Mean
3 3/7/2019 < 1.00 0.5 C.V. (default)
4 n
5
6 Mult Factor =
7 Max. Value
8 Max. Pred Cw
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
Use"PASTE SPECIAL -
Values" then "COPY" .
Maximum data points =
58
0.0000
0.5000
0.6000
3
3.00
0.500 ug/L
1.500 ug/L
06033 RPA 4.0.xlsm, data
- 13 - 4/26/2021

REASONABLE POTENTIAL ANALYSIS
Par21
Zinc
Date Data BDL=1/2DL Results
1 6/6/2017 42 42 Std Dev.
2 9/14/2018 26.8 26.8 Mean
3 3/7/2019 26 26 C.V. (default)
4 n
5
6 Mult Factor =
7 Max. Value
8 Max. Pred Cw
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
Use "PASTE SPECIAL
Values" then "COPY"
. Maximum data
points = 58
Par22
Chloroform
9.0155
31.6000
0.6000
3
3.00
42.0 ug/L
126.0 ug/L
Use "PASTE SPEC
Values" then "COI
Maximum data poin
Date Data BDL=1/2DL Results
1 6/6/2017 25 25 Std Dev. 4.7258
2 9/14/2018 16 16 Mean 21.3333
3 3/7/2019 23 23 C.V. (default) 0.6000
4 n 3
5
6 Mult Factor = 3.00
7 Max. Value 25.000000
8 Max. Pred Cw 75.000000
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
-14-
06033 RPA 4.0.xlsm, data
4/26/2021

REASONABLE POTENTIAL ANALYSIS
;IAL-
is-58
Par23
Chlorodibromomethane
Date Data BDL=1/2DL Results
1 6/6/2017 1.9 1.9 Std Dev.
2 9/14/2018 2.2 2.2 Mean
3 3/7/2019 < 1 0.5 C.V. (default)
4 n
5
6 Mult Factor =
pg/L 7 Max. Value
pg/L 8 Max. Pred Cw
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
Use "PASTE SPECIAL -Values" then
"COPY" . Maximum data points = 58
0.9074
1.5333
0.6000
3
3.00
2.200000 pg/L
6.600000 pg/L
Par24
Dichlorobromomet
Date Data BDL=1/2DL
1 6/6/2017 7 7
2 9/14/2018 6.1 6.1
3 3/7/2019 3.7 3.7
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
06033 RPA 4.0.xlsm, data
- 15 - 4/26/2021

REASONABLE POTENTIAL ANALYSIS
hane
Results
Std Dev.
Mean
C.V. (default)
n
Mult Factor =
Max. Value
Max. Pred Cw
Use "PASTE SPECIAL -
Values" then "COPY" .
Maximum data points = 58
1.7059
5.6000
0.6000
3
3.00
7.000000 pg/L
21.000000 pg/L
-16-
06033 RPA 4.0.xlsm, data
4/26/2021

NC0006033 Eagle Road WWTP 4/26/2021
BOD monthly removal rate
Month RR (%) Month RR (%)
May-16
June-16
July-16
August-16
September-16
October-16
November-16
December-16
January-17
February-17
March-17
April-17
May-17
June-17
July-17
August-17
September-17
October-17
November-17
December-17
January-18
February-18
March-18
April-18
May-18
June-18
July-18
August-18
September-18
October-18
96.57
96.65
96.18
95.55
98.07
98.56
98.56
98.40
98.57
99.15
98.61
98.30
98.20
97.31
97.85
97.43
98.72
98.93
99.27
99.18
98.61
99.00
98.56
97.82
97.52
98.07
98.55
97.19
97.76
98.90
November-18
December-18
January-19
February-19
March-19
April-19
May-19
June-19
July-19
August-19
September-19
October-19
November-19
December-19
January-20
February-20
March-20
April-20
May-20
June-20
July-20
August-20
September-20
October-20
November-20
December-20
January-21
February-21
March-21
April-21
Overall CBOD removal rate
98.59
98.13
98.70
98.65
99.04
98.66
98.37
98.38
97.34
97.23
98.36
99.26
99.25
98.44
98.91
98.91
97.95
97.71
95.98
98.64
98.64
99.09
99.44
99.35
99.47
99.54
99.54
99.46
98.33
TSS monthly removal rate
Month RR (%) Month
RR (%)
May-16
June-16
July-16
August-16
September-16
October-16
November-16
December-16
January-17
February-17
March-17
April-17
May-17
June-17
July-17
August-17
September-17
October-17
November-17
December-17
January-18
February-18
March-18
April-18
May-18
June-18
July-18
August-18
September-18
October-18
98.74
98.84
98.44
98.13
99.19
99.29
99.38
98.92
99.12
99.36
98.90
99.04
99.06
97.74
98.69
97.96
99.13
98.99
98.84
99.19
98.00
98.85
99.02
99.07
98.66
99.28
99.27
98.20
98.11
98.83
November-18
December-18
January-19
February-19
March-19
April-19
May-19
June-19
July-19
August-19
September-19
October-19
November-19
December-19
January-20
February-20
March-20
April-20
May-20
June-20
July-20
August-20
September-20
October-20
November-20
December-20
January-21
February-21
March-21
April-21
Overall TSS removal rate
97.36
97.66
96.85
98.92
99.14
98.91
99.05
99.20
98.85
99.10
98.25
99.14
99.29
98.94
97.87
97.74
98.13
98.92
98.10
98.94
97.96
99.25
99.38
99.18
98.79
99.28
99.49
98.60
98.70

NH3/TRC WLA Calculations
Facility:Eagle Road Wastewater Treatment Plant (WWTP)
PermitNo. NC0006033
Prepared By: Diana Yitbarek
Enter Design Flow (MGD):
Enter s7Q10 (cfs):
Enter w7Q10 (cfs):
4
125
230
Total Residual Chlorine (TRC)
Daily Maximum Limit (ug/I)
s7Q10 (CFS)
DESIGN FLOW (MGD)
DESIGN FLOW (CFS)
STREAM STD (UG/L)
Upstream Bkgd (ug/I)
IWC (%)
Allowable Conc. (ug/I)
Maintain limit at 28 ug/I
Fecal Coliform
Monthly Average Limit:
(If DF >331; Monitor)
(If DF<331; Limit)
Dilution Factor (DF)
Maintain 200/100 ml MA limit
Ammonia (Summer)
Monthly Average Limit (mg NH3-N/I)
125 s7Q10 (CFS)
4 DESIGN FLOW (MGD)
6.2 DESIGN FLOW (CFS)
17.0 STREAM STD (MG/L)
0 Upstream Bkgd (mg/I)
4.73 IWC (%)
360 Allowable Conc. (mg/I)
Current MA limit: 4.0 mg/I
Maintain limit
Ammonia (Winter)
Monthly Average Limit (mg NH3-N/I)
w7Q10 (CFS)
200/100m1 DESIGN FLOW (MGD)
DESIGN FLOW (CFS)
STREAM STD (MG/L)
21.16 Upstream Bkgd (mg/I)
IWC (%)
Allowable Conc. (mg/I)
Current MA limit: 4.0 mg/I
Maintain limit
Total Residual Chlorine
1. Cap Daily Max limit at 28 ug/I to protect for acute toxicity
Ammonia (as NH3-N)
1. If Allowable Conc > 35 mg/I, Monitor Only
2. Monthly Avg limit x 3 = Weekly Avg limit (Municipals)
3. Monthly Avg limit x 5 = Daily Max limit (Non-Munis)
If the allowable ammonia concentration is > 35 mg/L, no limit shall be imposed
125
4
6.2
1.0
0.22
4.73
16.7
230
4
6.2
1.8
0.22
2.62
60.4
Fecal Coliform
1. Monthly Avg limit x 2 = 400/100 ml = Weekly Avg limit (Municipals) = Daily Max limit (Non -Muni)

Eagle Road WWTP/NC0006033
Mercury Data Statistics (Method 1631E)
2017
2018
2019
# of Samples
1
1
1
Annual Average, ng/L
0.5
1.6
1.2
Maximum Value, ng/L
0.50
1.62
1.16
TBEL, ng/L
47
WQBEL, ng/L
253.9

Whole Effluent Toxicity Testing and Self Monitoring Summary
Correc, Dept Of (McCain Hospital-001) NC0035904/001 County: Hoke Region: FRO Basin: LUM50 Jan Apr Jul Oct SOC_JOC:
Ceri7dPF Begin: 8/1/2009 chr lim: 67% NonComp: Single 7Q10: 0.15 PF: 0.20 IWC: 67.4 Freq: Q
J F M A M J J A S 0 N D
2017 Pass Pass Pass - - Pass -
2018 Pass - - Pass - - Pass - - Pass -
2019 Pass - - Pass - - Pass - - Pass -
2020 Pass - - Pass - - Fail 23.7 >100% Pass -
2021 Pass - - - - -
Cousins Real Estate -Gateway Village NC0086517/001 County: Mecklenberg Region: MRO Basin: CTB34 Jan Apr Jul Oct SOC JOC:
Ceri7dPF Begin: 9/1/2015 chr lim: 90% NonComp: Single 7Q10: 0 PF: 0.050 IWC: 100 Freq: Q
J F M A M J J A S 0 N D
2017 Pass Pass Pass Pass -
2018 Pass - - Pass - - Pass - Pass - Pass
2019 Pass - - Pass - - Pass - - Pass - -
2020 Pass - - Pass - - Pass - - Pass - -
2021 Pass - - - - - - - -
CPI -Capital Power -Roxboro Plant NC0065081/003 County: Person Region: RRO Basin: ROA05 Feb May Aug Nov SOC JOC:
Ceri7dPF Begin: 12/1/2012 chr lim: 90% NonComp: Single 7Q10: 0.0 PF: VAR IWC: 100 Freq: Q
J F M A M J J A 5 0 N D
2017 >100 >100 - - 94.9 - >100
2018 - 82.2 31.8 >100 >100 >100 - >100
2019 >100 >100 >100 Pass
2020 - >100 - - >100 >100(P) - - >100
Cramerton WWTP (Eagle Rd)(2 Rivers) NC0006033/001 County: Gaston Region: MRO Basin: CTB36 Mar Jun Sep Dec SOC_JOC:
Ceri7dPF Begin: 3/1/2010 chr lim: 4.7% NonComp: Single 7Q10: 125 PF: 4.0 IWC: 4.7 Freq: Q
J F M A M J J A S 0 N D
2017 Pass Pass - - Pass - - Pass
2018 Pass - - Pass - - Pass >18.8(P) - - Pass >18.8(P)
2019 Pass >18.8(P) - - Pass - Pass - - Pass
2020 - Pass - Pass - - Pass - - Pass
2021 - Pass - -
Craven Co. Wood Energy-001 NC0075281/001 County: Craven Region: WARO Basin: NEU08 Mar Jun Sep Dec SOC JOC:
Ceri7dPF Begin: 7/1/2008 Chr Lim: 69% - rerout NonComp: Single 7Q10: 0.14 PF: 0.20 IWC: 69 Freq: Q
J F M A M J J A S 0 N D
2017 - - H - H - - H - - H
2018 H H - - H - - H
2019 - H - H - H - - H
2020 - - H - - H - - H - - H
Legend: P= Fathead minnow (Pimnhales oromelas). H=No Flow (facility is active). s = Split test between Certified Labs
Page 27 of 117

Effluent Toxicity Report Form -Chronic Fathead Minnow Multi -Concentration Test
Date:6/14/2018
Facility: Gastonia - Eagle
Laboc4to : Merits
x
Signature of Operator nXtesporr ssiOle Charge
X /
Signature of Laboratory Supervisor
NPDES # NC00 6033
P
ipe #:
County: Gaston
Comments
MAIL ORIGINAL TO:
Water Sciences Section
Aquatic Toxicology Branch
Division of Water Resources
1621 Mail Service Center
Raleigh, N.C. 27699-1621
Test Initiation Date/Time
% Eff.
Control
Rep!.
Surviving #
Original #
Wt/original (mg)
1.18
Surviving #
Original #
Wt/original (mg)
2.35
Surviving #
Original #
Wt/original (mg)
4.7
Surviving #
Original #
Wt/original (mg)
9.4
Surviving #
Original #
Wt/original (mg)
18.8
Surviving #
Original #
Wt/original (mg)
Water Quality Data
Control
pH (SU) !nit/Fin
DO (mg/L) Init/Fin
Temp (C) Init/Fin
High Concentration
pH (SU) !nit/Fin
DO (mglL) Init/Fin
Temp (C) init/Fin
Sample
Collection Start Date
Grab
Composite (Duration)
Hardness (mg/L)
' Alkalinity (mg/L)
Conductivity (umhos/cm)
Chlorine(mglL)
Temp. at Receipt (°C)
Dilution H2O Batch #
Hardness (mg/L)
Alkalinity (mglL)
Conductivity (umhoslcm)
6/5/2018
1
2
5:00 PM
3
4
Avg Wt1Surv. Control
9
10
9
9
10
10
10
10
0.595
0.672
0.640
0.807
9
10
9
10
10
10
10
10
0.697
0.759
0.686
0.579
10
9
10
10
10
10
10
10
0.690
0.797
0.707
0,742
10
10
10
10
10
10
10
10
0.702
0.754
0.805
0.753
10
10
10
10
10
10
10
10
0.683
0.740
0.626
0,636
10
10
10
10
10
10
10
10
0.773
0.682
0.800
0.683
Day
% Survival
Avg Wt (mg)
% Survival
Avg Wt (mg)
% Survival
Avg Wt (mg)
% Survival
Avg Wt (mg)
% Survival
Avg Wt (mg)
% Survival
Avg Wt (mg)
0.735
92.5
0.679
95.0
0.680
97.5
0.734
100.0
0.754
100.0
0.671
100.0
0.735
Test Organisms
r. Cultured In -House
[v Outside Supplier
Hatch Date: 6/4/18
Hatch Time: 3:00 pm CT
0
2
3
4
5
6
8.19 /
7.93
8.19 /
7.82
8.03 1
7.76
8.09 /
8.10
8.23 /
7.75
8.19 /
7.90
8.04 /
7.65
7.97 /
6.62
7.44 1
6.02
7.79 /
6.30
7.56 /
8.05
8.20 /
7.04
8.13 /
6.97
7.59 /
5.89
24.9 /
25.0
24.1 1
24.5
24.3 /
25.0
24.3 /
25.0
24.1 1
24.3
24,4 /
24.2
24.4 1
24.3
0
2
3
4
5
6
8.12 1
7.81
8.13 /
7.81
8.09 /
7.63
7.97 1
8.11
8.15 /
7.73
8.07 /
7.78
7,94 /
7.57
8.01 1
6.48
7.45 /
6.16
7.85 1
6.39
7.74 /
8.18
8.29 /
6.91
8.06 1
6.93
7.54 /
5.84
24.5 /
24.5
24.7 /
24.5
24.1 /
24.6
25.2 /
24.6
24.1 /
24.7
25.7 /
24,7
24.4 1
24.7
1
2
3
6/4/2018
6/6/2018
6/7/2018
23.9
24.1
23.8
40
38
38
24
22
19
455
475
442
<0.1
<0.1
<0.1
1.3
1,6
1.0
1273
43
57
191
1274
1275
46
46
53
54
201
199
1276
44
56
195
Normal
Horn. Var,
NOEC
LOEC
ChV
Method
Survival Growth
Yes 171
FE
18.8 18.8
>18.8 >18.8
>18.8 >18.8
Steel's Dunnett's
Overall Result
ChV
>18.8
Stats
Conc.
1.18
2.35
4.7
9.4
Survival
Critical Calculated
10 20
0
10
10
22
24
24
Growth
Critical Calculated
2,41-0.0388
2.41
-1.2315
2.41-1.6642
2.41 0.1609
18.8
10
24
2.41-1.2426

Average of Value
Parameter Location
00010 - Temperature, Wati Diff
Years Date Day Downstream Upstream _
201 Jun 1 24.4 24.3
2 24.7 24.3
3 23.8 23.6
6 24.8 24.5
7 24.7 24.6
8 24.6 23.5
13 26.1 26.4
14 26.6 26.9
15 27.3 27.5
20 25.9 25.5
21 25.9 25.7
22 27.8 27.8
27 28.0 27.6
28 26.8 25.7
29 25.8 25.5
5 26.9 27.0
6 27.1 27.2
8 26.8 26.5
11 27.7 27.9
12 27.3 27.1
13 29.1 29.1
18 26.3 26.0
19 28.3 28.3
20 29.2 29.2
25 29.6 30.6
26 29.8 29.5
27 31.0 31.7
1 29.6 28.9
2 28.7 28.1
31 27.9 24.6
8 27.3 26.9
9 27.5 27.1
11 26.8 27.0
15 28.3 28.9
16 29.0 28.7
17 29.9 30.1
22 27.9 27.8
23 27.8 26.8
24 27.4 27.2
29 27.6 27.8
30 27.3 27.4
31 27.4 27.2
Sep 6 25.0 25.0
8 25.6 26.9
9 26.4 27.7
13 26.6 26.3
15 26.6 26.3
16 26.2 26.0
20 26.0 25.5
22 25.1 24.7
Jul
Aug
-0.1
-0.4
-0.2
-0.3
-0.1
-1.1
0.3
0.3
0.2
-0.4
-0.2
0.0
-0.4
-1.1
-0.3
0.1
0.1
-0.3
0.2
-0.2
0.0
-0.3
0.0
0.0
1.0
-0.3
0.7
-0.7
-0.6
-3.3
-0.4
-0.4
0.2
0.6
-0.3
0.2
-0.1
-1.0
-0.2
0.2
0.1
-0.2
0.0
1.3
1.3
-0.3
-0.3
-0.2
-0.5
-0.4
F-Test Two -Sample for Variances
Variable 1
Variable 2
Mean
Variance
Observations
df
F
P(F<=f) one -tail
F Critical one -tail
20.62534884
52.7262324
430
429
1.014710202
0.439931545
1.172343492
20.58255814
51.9618629
430
429
Comment: The variance of Variable .
The variances of the two sets are equal.
t-Test: Two -Sample Assuming Equal Variances
Variable 1
Variable 2
Mean
Variance
Observations
Pooled Variance
Hypothesized Mea
df
t Stat
P(T<=t) one -tail
t Critical one -tail
P(T<=t) two -tail
t Critical two -tail
20.62534884
52.7262324
430
52.34404765
0
858
0.08672313
0.465455912
1.646631512
0.930911824
1.962732708
20.58255814
51.9618629
430
Comment: We look at the p-value, t\ .
Conclusion: There is no statistically .

2011 Sep
Oct
Nov
Deq
201
Jan
Feb
Mar
Apr
Mays
Jun
Jul
23 24.7 24.5 -0.2
26 24.4 23.5 -0.9
29 24.0 24.3 0.3
30 23.6 23.8 0.2
22.0 23.0 1.0
19.0 18.0 -1.0
20.0 21.0 1.0
16.0 16.0 0.0
17.0 17.0 0.0
13.0 12.0 -1.0
11.0 12.0 1.0
9.0 9.0 0.0
9.0 9.0 0.0
10.0 10.0 0.0
6.0 6.0 0.0
7.0 7.0 0.0
11.0 11.0 0.0
8.0 8.0 0.0
6.0 6.0 0.0
10.0 11.0 1.0
12.0 12.0 0.0
7.0 7.0 0.0
8.0 8.0 0.0
12.0 12.0 0.0
11.0 11.0 0.0
13.0 13.0 0.0
12.0 13.0 1.0
8.0 8.0 0.0
14.0 15.0 1.0
18.0 17.0 -1.0
17.0 17.0 0.0
17.0 17.0 0.0
20.0 20.0 0.0
15.0 16.0 1.0
21.0 21.0 0.0
16.0 16.0 0.0
20.0 20.0 0.0
22.0 22.0 0.0
22.0 22.0 0.0
23.0 22.0 -1.0
1 23.0 23.0 0.0
5 24.0 24.0 0.0
7 24.0 23.0 -1.0
8 23.0 23.0 0.0
12 25.0 25.0 0.0
13 25.0 26.0 1.0
14 26.0 26.0 0.0
19 26.0 26.0 0.0
20 26.0 26.0 0.0
21 25.0 25.0 0.0
26 24.0 24.0 0.0
27 25.0 25.0 0.0
28 24.0 24.0 0.0
5 26.0 26.0 0.0
6 27.0 27.0 0.0
4
11
18
28
31
11
14
21
28
5
12
19
27
3
13
17
23
30
6
13
20
28
8
15
22
29
5
12
19
26
1
8
15
22
30
31

201'
Jul
7
11
12
13
17
18
19
24
25
26
31
Aug
Sep
1
2
7
9
10
14
15
16
21
22
23
28
29
30
5
7
8
11
12
13
18
19
20
26
27
28
Oct
6
9
19
26
30
Nov
6
15
20
Dec
1
7
15
19
29
201 Jan
2
10
19
22
29
27.0
27.0
27.0
28.0
28.0
28.0
28.0
29.0
30.0
29.0
27.0
27.0
26.0
26.0
26.0
25.0
27.0
26.0
26.0
29.0
29.0
28.0
25.0
25.0
24.0
24.0
22.0
21.0
20.0
19.0
19.0
23.0
24.0
24.0
24.0
25.0
25.0
21.0
22.0
18.0
15.0
13.0
16.0
10.0
10.0
9.0
10.0
5.0
6.0
5.0
2.0
2.0
3.0
4.0
8.0
27.0
27.0
28.0
29.0
28.0
29.0
28.0
29.0
30.0
28.0
26.0
26.0
26.0
26.0
25.0
25.0
26.0
26.0
26.0
29.0
28.0
29.0
25.0
24.0
24.0
23.0
21.0
21.0
19.0
19.0
19.0
23.0
23.0
24.0
24.0
25.0
25.0
23.0
22.0
17.0
15.0
12.0
16.0
10.0
10.0
9.0
10.0
5.0
6.0
4.0
1.0
3.0
3.0
4.0
9.0
0.0
0.0
1.0
1.0
0.0
1.0
0.0
0.0
0.0
-1.0
-1.0
-1.0
0.0
0.0
-1.0
0.0
-1.0
0.0
0.0
0.0
-1.0
1.0
0.0
-1.0
0.0
-1.0
-1.0
0.0
-1.0
0.0
0.0
0.0
-1.0
0.0
0.0
0.0
0.0
2.0
0.0
-1.0
0.0
-1.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
-1.0
-1.0
1.0
0.0
0.0
1.0

201
Feb
Mar
Apr
May
Jun
Jul
Aug
9 7.0 7.0 0.0
12 11.0 11.0 0.0
19 13.0 13.0 0.0
26 16.0 16.0 0.0
5 11.0 10.0 -1.0
13 8.0 8.0 0.0
19 13.0 13.0 0.0
26 9.0 9.0 0.0
16.0 16.0 0.0
13.0 12.0 -1.0
17.0 17.0 0.0
16.0 16.0 0.0
15.0 15.0 0.0
20.0 20.0 0.0
24.0 24.0 0.0
22.0 22.0 0.0
22.0 22.0 0.0
4 24.0 24.0 0.0
5 23.0 23.0 0.0
6 22.0 22.0 0.0
11 26.0 25.0 -1.0
12 25.0 24.0 -1.0
13 24.0 24.0 0.0
18 28.0 27.0 -1.0
19 27.0 27.0 0.0
20 28.0 27.0 -1.0
25 28.0 27.0 -1.0
26 27.0 27.0 0.0
27 26.0 26.0 0.0
2 28.0 28.0 0.0
3 28.0 28.0 0.0
6 28.0 28.0 0.0
9 26.0 25.0 -1.0
10 27.0 27.0 0.0
12 27.0 28.0 1.0
16 28.0 27.0 -1.0
17 28.0 28.0 0.0
18 28.0 28.0 0.0
23 27.0 27.0 0.0
24 25.0 25.0 0.0
26 25.0 25.0 0.0
30 27.0 28.0 1.0
31 27.0 28.0 1.0
1 27.0 27.0 0.0
6 26.0 26.0 0.0
7 26.0 26.0 0.0
8 27.0 27.0 0.0
13 27.0 27.0 0.0
14 27.0 27.0 0.0
15 27.0 27.0 0.0
20 28.0 28.0 0.0
21 27.0 26.0 -1.0
22 27.0 27.0 0.0
27 25.0 26.0 1.0
28 26.0 26.0 0.0
2
9
16
26
30
7
14
21
29

201, Au
9
Sep
Oct
29 26.0 26.0 0.0
27.0 27.0 0.0
28.0 28.0 0.0
28.0 28.0 0.0
28.0 27.0 -1.0
27.0 27.0 0.0
27.0 27.0 0.0
23.0 23.0 0.0
24.0 23.0 -1.0
24.0 24.0 0.0
24.0 24.0 0.0
24.0 24.0 0.0
24.0 24.0 0.0
25.0 25.0 0.0
24.0 24.0 0.0
19.0 19.0 0.0
15.0 14.0 -1.0
13.0 13.0 0.0
14.0 14.0 0.0
9.0 9.0 0.0
11.0 11.0 0.0
10.0 10.0 0.0
12.0 12.0 0.0
5.0 5.0 0.0
9.0 9.0 0.0
7.0 7.0 0.0
12.0 12.0 0.0
10.0 10.0 0.0
6.0 6.0 0.0
6.0 6.0 0.0
6.0 7.0 1.0
8.0 8.0 0.0
9.0 9.0 0.0
9.0 9.0 0.0
10.0 11.0 1.0
11.0 10.0 -1.0
11.0 11.0 0.0
11.0 11.0 0.0
13.0 13.0 0.0
14.0 14.0 0.0
17.0 17.0 0.0
17.0 17.0 0.0
15.0 15.0 0.0
19.0 20.0 1.0
21.0 21.0 0.0
21.0 20.0 -1.0
22.0 23.0 1.0
25.0 25.0 0.0
3 24.0 24.0 0.0
4 24.0 23.0 -1.0
5 24.0 24.0 0.0
10 22.0 22.0 0.0
12 21.0 21.0 0.0
14 20.0 20.0 0.0
17 23.0 23.0 0.0
5
6
7
10
12
13
18
19
20
24
25
26
5
9
17
23
29
Nov
Dec
5
13
20
26
3
11
17
26
201
Jan
4
7
14
23
28
Feb
4
13
18
26
Mar
4
11
20
25
Apr
5
9
17
22
30
Mays
6
13
20
28
Jun

201' Jun
Jul
Aug
Sep
Oct
Nov
Dec
18 24.0 24.0 0.0
19 23.0 24.0 1.0
24 24.0 24.0 0.0
26 24.0 24.0 0.0
27 24.0 25.0 1.0
2 27.0 27.0 0.0
3 28.0 27.0 -1.0
5 27.0 26.0 -1.0
8 28.0 28.0 0.0
11 26.0 26.0 0.0
12 27.0 26.0 -1.0
15 28.0 27.0 -1.0
17 28.0 27.0 -1.0
18 28.0 28.0 0.0
23 28.0 27.0 -1.0
24 25.0 25.0 0.0
25 24.0 24.0 0.0
29 26.0 26.0 0.0
30 26.0 26.0 0.0
31 26.0 26.0 0.0
5 26.0 26.0 0.0
7 27.0 26.0 -1.0
8 27.0 27.0 0.0
12 27.0 27.0 0.0
13 28.0 28.0 0.0
14 27.0 27.0 0.0
20 27.0 27.0 0.0
21 27.0 27.0 0.0
22 28.0 28.0 0.0
26 23.0 23.0 0.0
27 23.0 23.0 0.0
28 24.0 24.0 0.0
4 26.0 27.0 1.0
51 26.0 26.0 0.0
6 25.0 26.0 1.0
9 26.0 26.0 0.0
10 27.0 28.0 1.0
11 29.0 28.0 -1.0
18 26.0 25.0 -1.0
19 25.0 24.0 -1.0
20 24.0 23.0 -1.0
24 25.0 24.0 -1.0
25 25.0 24.0 -1.0
26 25.0 25.0 0.0
27.0 26.0 -1.0
21.0 21.0 0.0
20.0 19.0 -1.0
16.0 17.0 1.0
18.0 18.0 0.0
4 12.0 13.0 1.0
13 9.0 9.0 0.0
20 10.0 10.0 0.0
25 10.0 10.0 0.0
4 10.0 10.0 0.0
9 8.0 8.0 0.0
4
9
15
22
29

201 ! Dec
202
Jan
Feb
Mar
Apr
May
Jun
Jul
Aug
16 9.0 9.0 0.0
26 9.0 9.0 0.0
31 11.0 11.0 0.0
8.0 8.0 0.0
14.0 14.0 0.0
5.0 5.0 0.0
8.0 8.0 0.0
5 11.0 11.0 0.0
7 13.0 13.0 0.0
13 13.0 13.0 0.0
18 9.0 9.0 0.0
25 10.0 10.0 0.0
4 11.0 11.0 0.0
9 10.0 11.0 1.0
181 14.0 15.0 1.0
25 14.0 14.0 0.0
1 16.0 16.0 0.0
7 17.0 17.0 0.0
151 16.0 16.0 0.0
21 16.0 16.0 0.0
27 17.0 18.0 1.0
19.0 18.0 -1.0
15.0 15.0 0.0
15.0 15.0 0.0
19.0 19.0 0.0
2 21.0 22.0 1.0
3 21.0 22.0 1.0
4 23.0 24.0 1.0
8 25.0 25.0 0.0
9 25.0 25.0 0.0
10 25.0 25.0 0.0
16 20.0 20.0 0.0
17 18.0 18.0 0.0
19 19.0 19.0 0.0
22 22.0 22.0 0.0
23 23.0 23.0 0.0
24 23.0 23.0 0.0
29 24.0 25.0 1.0
30I 25.0 24.0 -1.0
1 24.0 24.0 0.0
7 25.0 26.0 1.0
8 25.0 25.0 0.0
10 26.0 26.0 0.0
13 27.0 27.0 0.0
14 28.0 27.0 -1.0
16 27.0 27.0 0.0
21 28.0 28.0 0.0
22 27.0 27.0 0.0
23 28.0 28.0 0.0
27 28.0 28.0 0.0
29 28.0 28.0 0.0
30 27.0 27.0 0.0
3 27.0 27.0 0.0
4 25.0 26.0 1.0
5 26.0 27.0 1.0
8
15
23
27
5
13
21
26

2021 Aug
Sep
11
12
13
17
19
20
24
25
28
1
2
4
8
9
10
14
15
18
21
22
23
28
29
30
Oct
6
14
21
28
Nov
6
9
17
25
Dec
2
7
15
22
29
202
Jan
7
12
19
26
Feb
1
9
17
24
Mar
3
8
17
24
29
DO
26.0
26.0
26.0
24.0
24.0
24.0
24.0
24.0
26.0
25.0
25.0
25.0
24.0
23.0
24.0
24.0
24.0
20.0
18.0
18.0
18.0
19.0
19.0
19.0
16.0
18.0
16.0
17.0
13.0
15.0
14.0
11.0
10.0
9.0
10.0
9.0
6.0
8.0
7.0
6.0
8.0
6.0
8.0
8.0
9.0
12.0
10.0
11.0
14.0
15.0
26.0
26.0
26.0
24.0
25.0
24.0
24.0
24.0
26.0
25.0
25.0
25.0
23.0
23.0
23.0
25.0
24.0
20.0
18.0
18.0
17.0
19.0
20.0
19.0
17.0
18.0
17.0
17.0
13.0
16.0
14.0
11.0
10.0
9.0
10.0
9.0
6.0
8.0
7.0
6.0
8.0
6.0
8.0
8.0
9.0
12.0
11.0
11.0
14.0
14.0
0.0
0.0
0.0
0.0
1.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
-1.0
0.0
-1.0
1.0
0.0
0.0
0.0
0.0
-1.0
0.0
1.0
0.0
1.0
0.0
1.0
0.0
0.0
1.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
1.0
0.0
0.0
-1.0

Average of Value
Years
201
Date
Jun
Day
Jul
Parameter Location
00300 - Oxygen, Dissolvec Diff
Downstream Upstream _
7.7
7.7
8.4
8.2
8.0
7.9
8.8
7.2
7.0
7.8
7.5
7.6
7.3
7.4
7.8
Aug
Sep
7.7
7.6
8.0
8.2
7.9
7.8
9.3
7.5
7.3
8.0
7.6
7.9
7.0
7.0
7.5
7.5
8.5
7.1
7.1
6.9
7.6
7.3
7.2
7.1
6.9
7.2
7.7
7.0
6.7
7.5
7.4
7.5
7.4
6.8
7.8
7.3
6.6
6.7
6.9
7.8
6.5
6.8
7.3
7.2
7.3
6.8
7.3
6.8
6.8
6.9
7.1
7.6
8.2
7.2
6.7
7.2
7.4
7.3
7.3
6.9
6.8
7.4
7.2
7.0
6.8
7.6
7.7
7.6
7.5
6.6
7.5
7.6
6.7
6.8
7.1
7.9
7.1
7.2
7.6
7.4
7.3
7.0
7.3
6.9
7.0
7.2
7.6
0.0
0.1
0.4
0.0
0.1
0.1
-0.5
-0.3
-0.3
-0.2
-0.1
-0.3
0.3
0.4
0.3
0.1
-0.3
0.1
-0.4
0.3
-0.2
0.0
0.1
-0.2
-0.1
0.2
-0.5
0.0
0.1
0.1
0.3
0.1
0.1
-0.2
-0.3
0.3
0.1
0.1
0.2
0.1
0.6
0.4
0.3
0.2
0.0
0.2
0.0
0.1
0.2
0.3
0.5
F-Test Two -Sample for Variances
Variable 1
Variable 2
Mean
Variance
Observations
df
F
P(F<=f) one -tail
F Critical one -tail
8.845116279
2.910220849
430
429
1.08160643
0.208442859
1.172343492
8.934186047
2.690646772
430
429
Comment: The variance of Variable .
The variances of the two sets are equal.
t-Test: Two -Sample Assuming Equal Variances
Variable 1
Variable 2
Mean
Variance
Observations
Pooled Variance
Hypothesized Mea
df
t Stat
P(T<=t) one -tail
t Critical one -tail
P(T<=t) two -tail
t Critical two -tail
8.845116279
2.910220849
430
2.80043381
0
858
-0.780435277
0.21767498
1.646631512
0.43534996
1.962732708
8.934186047
2.690646772
430
Comment: We look at the p-value, t\ .
Conclusion: There is no statistically .

2011 Sep
Oct
Novi
Dec
201
Jan
Feb
Mar
Apr
May
Jun
Jul
26 9.0 8.1 -0.9
29 7.8 8.0 0.2
30 7.4 7.4 0.0
7.8 7.9 0.1
8.4 8.7 0.3
9.2 9.3 0.1
10.3 10.3 0.0
9.1 9.0 -0.1
11 9.7 9.6 -0.1
14 10.4 10.4 0.0
21 10.1 10.7 0.6
28 11.0 11.0 0.0
5 11.0 10.7 -0.3
12 12.9 12.6 -0.3
19 11.8 11.4 -0.4
27 11.7 11.4 -0.3
3 11.8 11.8 0.0
13 12.9 12.8 -0.1
17 11.3 11.0 -0.3
23 10.4 10.4 0.0
30 11.5 11.8 0.3
11.8 11.7 -0.1
10.9 10.4 -0.5
11.1 10.6 -0.5
10.5 10.3 -0.2
10.8 10.5 -0.3
10.3 10.4 0.1
10.5 10.3 -0.2
9.2 9.5 0.3
9.7 9.8 0.1
9.1 9.6 0.5
8.0 8.5 0.5
10.5 10.6 0.1
8.6 8.8 0.2
9.6 9.9 0.3
8.5 9.0 0.5
8.7 9.0 0.3
8.9 9.1 0.2
8.8 9.0 0.2
1 8.2 8.7 0.5
5 7.6 8.1 0.5
7 7.3 7.7 0.4
8 7.5 8.0 0.5
12 7.6 7.7 0.1
13 7.9 7.8 -0.1
14 7.9 8.0 0.1
19 7.5 7.9 0.4
20 7.2 7.4 0.2
21 7.1 7.4 0.3
26 7.7 7.9 0.2
27 7.6 7.8 0.2
28 7.6 7.8 0.2
5 7.3 7.5 0.2
6 7.5 7.7 0.2
7 7.4 7.7 0.3
4
11
18
28
31
6
13
20
28
8
15
22
29
5
12
19
26
1
8
15
22
30
31

201 Jul
Aug
Sep
Oct
Novi
Dec
201
Jan
Feb
11 7.2 7.4
12 7.4 7.4
13 7.4 7.3
17 7.1 7.3
18 7.3 7.5
19 7.6 7.7
24 6.6 6.8
25 7.0 7.1
26 6.5 6.8
311 7.0 7.2
1 7.0 7.1
2 7.2 7.2
7 6.9 7.0
9 7.4 7.7
10 7.4 7.4
14 7.4 7.6
15 7.6 7.9
16 7.8 8.0
21 6.9 7.2
22 6.7 7.1
23 6.9 7.2
28 7.1 7.3
29 6.9 7.2
30 7.0 7.4
5 7.5 7.5
7 8.4 8.5
8 9.0 9.1
11 8.4 8.6
12 9.4 9.4
13 9.7 9.5
18 8.2 8.1
19 7.8 8.0
20 8.0 8.1
26 7.8 8.1
27 7.4 7.5
28 7.4 7.4
6 8.3 8.3
9 8.3 8.3
19 8.3 8.6
26 9.6 9.9
30 10.1 10.6
9.8 9.8
10.4 10.6
10.3 10.5
11.9 11.6
11.2 11.6
12.8 12.6
12.5 12.0
12.6 12.6
13.1 13.0
14.3 13.9
14.6 15.0
13.3 13.2
12.1 11.9
9 11.6 11.7
6
15
20
1
7
15
19
29
2
10
19
22
29
0.2
0.0
-0.1
0.2
0.2
0.1
0.2
0.1
0.3
0.2
0.1
0.0
0.1
0.3
0.0
0.2
0.3
0.2
0.3
0.4
0.3
0.2
0.3
0.4
0.0
0.1
0.1
0.2
0.0
-0.2
-0.1
0.2
0.1
0.3
0.1
0.0
0.0
0.0
0.3
0.3
0.5
0.0
0.2
0.2
-0.3
0.4
-0.2
-0.5
0.0
-0.1
-0.4
0.4
-0.1
-0.2
0.1

201
Feb
12
19
26
Mar
5
13
19
26
Apr
May
Jun
Jul
Aug
2
9
16
26
30
7
14
21
29
4
5
6
11
12
13
18
19
20
25
26
27
2
3
6
9
10
12
16
17
18
23
24
26
30
31
1
6
7
8
13
14
15
20
21
22
27
28
29
10.6
10.2
9.4
10.9
11.7
9.9
10.8
9.8
10.3
9.6
10.1
9.2
8.4
8.4
8.7
8.9
8.6
8.7
8.6
7.8
7.7
8.8
8.0
8.0
7.8
7.4
7.8
7.6
7.3
7.2
7.4
7.6
8.5
7.5
7.2
7.3
7.4
7.5
8.2
8.2
7.1
7.6
7.4
7.7
7.8
7.8
7.5
7.9
7.0
7.0
6.9
7.5
7.6
7.4
7.0
11.3
10.3
9.5
11.2
12.1
10.0
11.0
9.9
10.5
9.6
10.3
9.4
8.7
9.0
8.8
8.9
8.7
8.9
7.8
8.0
8.0
9.0
8.3
8.1
7.9
7.5
8.0
7.8
7.6
7.4
7.5
8.0
8.8
7.6
7.2
7.3
7.5
7.5
8.2
8.2
7.5
7.8
7.8
7.9
7.8
8.0
7.8
8.2
7.4
7.6
7.4
7.9
7.6
7.7
7.3
0.7
0.1
0.1
0.3
0.4
0.1
0.2
0.1
0.2
0.0
0.2
0.2
0.3
0.6
0.1
0.0
0.1
0.2
-0.8
0.2
0.3
0.2
0.3
0.1
0.1
0.1
0.2
0.2
0.3
0.2
0.1
0.4
0.3
0.1
0.0
0.0
0.1
0.0
0.0
0.0
0.4
0.2
0.4
0.2
0.0
0.2
0.3
0.3
0.4
0.6
0.5
0.4
0.0
0.3
0.3

201 Sep
Oct
Nov
Dec
201
Jan
Feb
Mar
Apr
May
Jun
5 6.9 7.2 0.3
6 6.7 7.2 0.5
7 7.0 7.4 0.4
10 6.9 7.1 0.2
12 7.6 7.4 -0.2
13 7.2 7.3 0.1
18 8.5 8.6 0.1
19 8.3 8.5 0.2
20 8.1 8.4 0.3
24 7.5 7.8 0.3
25 7.8 8.0 0.2
26 7.9 8.2 0.3
5 7.7 8.0 0.3
9 7.5 7.7 0.2
17 8.7 8.9 0.2
23 9.7 10.1 0.4
29 10.4 10.6 0.2
10.2 10.1 -0.1
11.6 11.4 -0.2
11.1 11.1 0.0
11.8 11.8 0.0
10.9 10.9 0.0
12.9 12.9 0.0
11.3 11.8 0.5
12.6 12.5 -0.1
10.7 10.6 -0.1
11.3 11.4 0.1
12.4 12.4 0.0
12.5 12.5 0.0
12.4 12.4 0.0
11.8 11.7 -0.1
11.5 11.5 0.0
11.7 11.8 0.1
11.7 11.6 -0.1
10.9 11.0 0.1
11.4 11.5 0.1
11.4 11.3 -0.1
10.6 10.7 0.1
9.9 10.0 0.1
9.5 8.8 -0.7
9.9 10.0 0.1
10.4 10.4 0.0
9.4 9.5 0.1
8.8 8.8 0.0
8.9 9.1 0.2
8.4 8.6 0.2
7.8 8.2 0.4
3 7.9 8.2 0.3
4 7.9 8.3 0.4
5 8.1 8.4 0.3
10 8.1 8.4 0.3
12 8.3 8.5 0.2
14 8.5 8.7 0.2
17 9.3 9.3 0.0
18 8.7 8.7 0.0
5
13
20
26
3
11
17
26
4
7
14
23
28
4
13
18
26
4
11
20
25
5
9
17
22
30
6
13
20
28

201' Jun
Jul
Aug
Sep
Oct
Nov
Dec
19 8.2 8.4 0.2
24 8.0 8.2 0.2
26 8.0 8.2 0.2
27 8.1 8.3 0.2
2 7.6 8.0 0.4
3 7.5 7.7 0.2
5 7.2 7.4 0.2
8 7.7 7.9 0.2
11 7.6 7.8 0.2
12 7.6 7.8 0.2
15 8.3 8.5 0.2
17 7.9 8.1 0.2
18 7.5 8.3 0.8
23 7.1 7.4 0.3
24 7.9 8.0 0.1
25 8.2 8.3 0.1
29 7.8 8.0 0.2
30 7.7 8.0 0.3
31 7.6 7.8 0.2
5 7.5 7.7 0.2
7 7.9 8.2 0.3
8 7.7 8.1 0.4
12 7.7 7.8 0.1
13 7.6 7.8 0.2
14 7.6 7.1 -0.5
20 7.4 7.7 0.3
21 7.5 7.8 0.3
22 7.4 7.6 0.2
26 8.0 8.2 0.2
27 7.8 8.0 0.2
28 8.0 8.1 0.1
4 7.7 7.7 0.0
5 7.5 7.6 0.1
6 7.6 7.5 -0.1
9 7.9 7.8 -0.1
10 7.6 7.5 -0.1
11 7.6 7.6 0.0
18 7.6 7.5 -0.1
19 7.8 7.8 0.0
20 7.8 7.8 0.0
24 8.5 8.5 0.0
25 8.3 8.3 0.0
26 8.4 8.3 -0.1
4 7.4 7.3 -0.1
9 7.9 8.0 0.1
15 8.4 8.4 0.0
22 9.7 9.7 0.0
29 9.1 9.1 0.0
10.1 10.2 0.1
10.6 10.9 0.3
11.1 11.2 0.1
11.2 11.4 0.2
4 11.5 11.5 0.0
9 11.6 11.5 -0.1
16 11.8 11.8 0.0
4
13
20
25

201
202
Dec
Jan
Feb
Mar
Apr
Mayl
Jun
Jul
Aug
26 11.5 11.6 0.1
31 10.5 10.6 0.1
11.8 11.8 0.0
10.3 10.4 0.1
12.6 12.5 -0.1
12.1 12.2 0.1
11.4 11.2 -0.2
10.5 10.6 0.1
11.0 11.1 0.1
11.6 11.6 0.0
11.5 11.5 0.0
11.2 11.1 -0.1
11.4 11.2 -0.2
10.5 10.3 -0.2
10.4 10.4 0.0
9.6 9.5 -0.1
9.3 9.3 0.0
9.5 9.5 0.0
10.6 10.5 -0.1
9.4 9.6 0.2
9.0 9.2 0.2
10.2 10.4 0.2
10.1 10.1 0.0
9.1 9.1 0.0
2 8.7 8.8 0.1
3 8.5 8.7 0.2
4 8.3 8.4 0.1
8 8.1 8.1 0.0
9 8.1 8.1 0.0
10 8.1 8.1 0.0
16 9.0 8.9 -0.1
17 9.5 9.4 -0.1
19 9.3 9.2 -0.1
22 8.4 8.6 0.2
23 8.3 8.4 0.1
24 8.3 8.4 0.1
29 8.2 8.1 -0.1
30 8.2 8.1 -0.1
1 8.3 8.2 -0.1
71 8.1 8.1 0.0
8 8.2 8.1 -0.1
10 8.0 8.0 0.0
13 7.7 7.9 0.2
14 7.8 8.0 0.2
16 7.7 8.0 0.3
21 7.6 7.6 0.0
22 7.7 7.8 0.1
23 7.7 7.8 0.1
27 7.6 7.8 0.2
29 7.6 7.7 0.1
30 7.8 7.8 0.0
3 7.6 7.8 0.2
4 7.9 8.0 0.1
5 7.9 7.9 0.0
11 8.0 8.0 0.0
8
15
23
27
5
7
13
18
25
4
9
18
25
1
7
15
21
27
5
13
21
26

MONITORING REPORT(MR) VIOLATIONS for:
Report Date: 04/22/21 Page 1 01 5
Permit: NC0006033 MRs Betweei 6 - 2016 and 4 - 2021 Region: % Violation Category:% Program Category: %
Facility Name: % Param Nam(% County: % Subbasin:% Violation Action: %
Major Minor:
PERMIT: NC0006033
FACILITY: City of Gastonia - Eagle Road WWTP
COUNTY: Gaston REGION: Mooresville
Limit Violation
MONITORING UNIT OF
OUTFALL LOCATION PARAMETER VIOLATION FREQUENCY
REPORT DATE MEASURE
LIMIT
CALCULATED
VALUE Over
VIOLATION TYPE VIOLATION ACTION
06 - 2016 001 Effluent Chlorine, Total Residual 06/14/16 5 X week ug/I 28 32 14.3 Daily Maximum No Action, BPJ
Exceeded
06 - 2016 001 Effluent Chlorine, Total Residual 06/15/16 5 X week ug/I 28 29 3.6 Daily Maximum No Action, BPJ
Exceeded
06 - 2016 001 Effluent Chlorine, Total Residual 06/23/16 5 X week ug/I 28 34 21.4 Daily Maximum No Action, BPJ
Exceeded
06 - 2016 001 Effluent Chlorine, Total Residual 06/27/16 5 X week ug/I 28 36 28.6 Daily Maximum No Action, BPJ
Exceeded
06 - 2016 001 Effluent Chlorine, Total Residual 06/30/16 5 X week ug/I 28 33 17.9 Daily Maximum No Action, BPJ
Exceeded
07 - 2016 001 Effluent Chlorine, Total Residual 07/08/16 5 X week ug/I 28 39 39.3 Daily Maximum No Action, BPJ
Exceeded
07 - 2016 001 Effluent Chlorine, Total Residual 07/12/16 5 X week ug/I 28 34 21.4 Daily Maximum No Action, BPJ
Exceeded
07 - 2016 001 Effluent Chlorine, Total Residual 07/13/16 5 X week ug/I 28 41 46.4 Daily Maximum No Action, BPJ
Exceeded
07 - 2016 001 Effluent Chlorine, Total Residual 07/18/16 5 X week ug/I 28 31 10.7 Daily Maximum No Action, BPJ
Exceeded
07-2016 001 Effluent Chlorine, Total Residual 07/20/16 5 X week ug/I 28 32 14.3 Daily Maximum No Action, BPJ
Exceeded
07-2016 001 Effluent Chlorine, Total Residual 07/21/16 5 X week ug/I 28 34 21.4 Daily Maximum No Action, BPJ
Exceeded
07 - 2016 001 Effluent Chlorine, Total Residual 07/27/16 5 X week ug/I 28 43 53.6 Daily Maximum No Action, BPJ
Exceeded
07 - 2016 001 Effluent Chlorine, Total Residual 07/28/16 5 X week ug/I 28 37 32.1 Daily Maximum No Action, BPJ
Exceeded
08 - 2016 001 Effluent Chlorine, Total Residual 08/03/16 5 X week ug/I 28 37 32.1 Daily Maximum No Action, BPJ
Exceeded
08 - 2016 001 Effluent Chlorine, Total Residual 08/08/16 5 X week ug/I 28 33 17.9 Daily Maximum No Action, BPJ
Exceeded
08 - 2016 001 Effluent Chlorine, Total Residual 08/09/16 5 X week ug/I 28 39 39.3 Daily Maximum No Action, BPJ
Exceeded

MONITORING REPORT(MR) VIOLATIONS for:
Report Date: 04/22/21 Page 2 of 5
Permit: NC0006033 MRs Betweei 6 - 2016 and 4 - 2021 Region: % Violation Category:% Program Category: %
Facility Name: % Param Nam(% County: % Subbasin:% Violation Action: %
Major Minor: %
PERMIT: NC0006033
FACILITY: City of Gastonia - Eagle Road WWTP
COUNTY: Gaston REGION: Mooresville
Limit Violation
MONITORING UNIT OF
OUTFALL LOCATION PARAMETER VIOLATION FREQUENCY
REPORT DATE MEASURE
LIMIT
CALCULATED
VALUE Over
VIOLATION TYPE VIOLATION ACTION
08 - 2016 001 Effluent Chlorine, Total Residual 08/10/16 5 X week ug/I 28 37 32.1 Daily Maximum No Action, BPJ
Exceeded
08 - 2016 001 Effluent Chlorine, Total Residual 08/12/16 5 X week ug/I 28 37 32.1 Daily Maximum No Action, BPJ
Exceeded
08 - 2016 001 Effluent Chlorine, Total Residual 08/16/16 5 X week ug/I 28 37 32.1 Daily Maximum No Action, BPJ
Exceeded
08 - 2016 001 Effluent Chlorine, Total Residual 08/18/16 5 X week ug/I 28 37 32.1 Daily Maximum No Action, BPJ
Exceeded
08 - 2016 001 Effluent Chlorine, Total Residual 08/19/16 5 X week ug/I 28 32 14.3 Daily Maximum No Action, BPJ
Exceeded
08 - 2016 001 Effluent Chlorine, Total Residual 08/22/16 5 X week ug/I 28 42 50 Daily Maximum No Action, BPJ
Exceeded
08 - 2016 001 Effluent Chlorine, Total Residual 08/23/16 5 X week ug/I 28 33 17.9 Daily Maximum No Action, BPJ
Exceeded
08 - 2016 001 Effluent Chlorine, Total Residual 08/24/16 5 X week ug/I 28 42 50 Daily Maximum No Action, BPJ
Exceeded
08-2016 001 Effluent Chlorine, Total Residual 08/25/16 5 X week ug/I 28 34 21.4 Daily Maximum No Action, BPJ
Exceeded
08 - 2016 001 Effluent Chlorine, Total Residual 08/26/16 5 X week ug/I 28 40 42.9 Daily Maximum No Action, BPJ
Exceeded
08 - 2016 001 Effluent Chlorine, Total Residual 08/29/16 5 X week ug/I 28 41 46.4 Daily Maximum No Action, BPJ
Exceeded
09-2016 001 Effluent Chlorine, Total Residual 09/01/16 5 X week ug/I 28 36 28.6 Daily Maximum No Action, BPJ
Exceeded
09 - 2016 001 Effluent Chlorine, Total Residual 09/02/16 5 X week ug/I 28 32 14.3 Daily Maximum No Action, BPJ
Exceeded
09 - 2016 001 Effluent Chlorine, Total Residual 09/06/16 5 X week ug/I 28 31 10.7 Daily Maximum No Action, BPJ
Exceeded
09 - 2016 001 Effluent Chlorine, Total Residual 09/07/16 5 X week ug/I 28 35 25 Daily Maximum No Action, BPJ
Exceeded
09 - 2016 001 Effluent Chlorine, Total Residual 09/09/16 5 X week ug/I 28 47 67.9 Daily Maximum No Action, BPJ
Exceeded

MONITORING REPORT(MR) VIOLATIONS for:
Report Date: 04/22/21 Page 3 of 5
Permit: NC0006033 MRs Betweei 6 - 2016 and 4 - 2021 Region: % Violation Category:% Program Category: %
Facility Name: % Param Nam(% County: % Subbasin:% Violation Action: %
Major Minor: %
PERMIT: NC0006033
FACILITY: City of Gastonia - Eagle Road WWTP
COUNTY: Gaston REGION: Mooresville
Limit Violation
MONITORING UNIT OF
OUTFALL LOCATION PARAMETER VIOLATION FREQUENCY
REPORT DATE MEASURE
LIMIT
CALCULATED
VALUE Over
VIOLATION TYPE VIOLATION ACTION
09 - 2016 001 Effluent Chlorine, Total Residual 09/12/16 5 X week ug/I 28 39 39.3 Daily Maximum No Action, BPJ
Exceeded
09 - 2016 001 Effluent Chlorine, Total Residual 09/15/16 5 X week ug/I 28 37 32.1 Daily Maximum No Action, BPJ
Exceeded
09 - 2016 001 Effluent Chlorine, Total Residual 09/20/16 5 X week ug/I 28 34 21.4 Daily Maximum No Action, BPJ
Exceeded
09-2016 001 Effluent Chlorine, Total Residual 09/21/16 5 X week ug/I 28 41 46.4 Daily Maximum No Action, BPJ
Exceeded
09 - 2016 001 Effluent Chlorine, Total Residual 09/26/16 5 X week ug/I 28 32 14.3 Daily Maximum No Action, BPJ
Exceeded
09 - 2016 001 Effluent Chlorine, Total Residual 09/27/16 5 X week ug/I 28 35 25 Daily Maximum No Action, BPJ
Exceeded
09 - 2016 001 Effluent Chlorine, Total Residual 09/30/16 5 X week ug/I 28 31 10.7 Daily Maximum No Action, BPJ
Exceeded
10 - 2016 001 Effluent Chlorine, Total Residual 10/03/16 5 X week ug/I 28 31 10.7 Daily Maximum No Action, BPJ
Exceeded
10-2016 001 Effluent Chlorine, Total Residual 10/05/16 5 X week ug/I 28 29 3.6 Daily Maximum No Action, BPJ
Exceeded
10 - 2016 001 Effluent Chlorine, Total Residual 10/13/16 5 X week ug/I 28 32 14.3 Daily Maximum No Action, BPJ
Exceeded
12 - 2016 001 Effluent Chlorine, Total Residual 12/15/16 5 X week ug/I 28 30 7.1 Daily Maximum No Action, BPJ
Exceeded
04 - 2017 001 Effluent Chlorine, Total Residual 04/05/17 5 X week ug/I 28 36 28.6 Daily Maximum No Action, BPJ
Exceeded
05 - 2017 001 Effluent Chlorine, Total Residual 05/23/17 5 X week ug/I 28 29 3.6 Daily Maximum No Action, BPJ
Exceeded
05 - 2017 001 Effluent Chlorine, Total Residual 05/26/17 5 X week ug/I 28 31 10.7 Daily Maximum No Action, BPJ
Exceeded
09 - 2017 001 Effluent Chlorine, Total Residual 09/12/17 5 X week ug/I 28 43 53.6 Daily Maximum No Action, BPJ
Exceeded
10 - 2017 001 Effluent Chlorine, Total Residual 10/02/17 5 X week ug/I 28 29 3.6 Daily Maximum No Action, BPJ
Exceeded

MONITORING REPORT(MR) VIOLATIONS for:
Report Date: 04/22/21 Page 4 of 5
Permit: NC0006033 MRs Betweei 6 - 2016 and 4 - 2021 Region: % Violation Category:% Program Category: %
Facility Name: % Param Nam(% County: % Subbasin:% Violation Action: %
Major Minor: %
PERMIT: NC0006033
FACILITY: City of Gastonia - Eagle Road WWTP
COUNTY: Gaston REGION: Mooresville
Limit Violation
MONITORING UNIT OF
OUTFALL LOCATION PARAMETER VIOLATION FREQUENCY
REPORT DATE MEASURE
LIMIT
CALCULATED
VALUE Over
VIOLATION TYPE VIOLATION ACTION
10 - 2017 001 Effluent Chlorine, Total Residual 10/03/17 5 X week ug/I 28 42 50 Daily Maximum No Action, BPJ
Exceeded
10 - 2017 001 Effluent Chlorine, Total Residual 10/17/17 5 X week ug/I 28 43 53.6 Daily Maximum No Action, BPJ
Exceeded
01 -2018 001 Effluent Chlorine, Total Residual 01/05/18 5 X week ug/I 28 29 3.6 Daily Maximum No Action, BPJ
Exceeded
02 - 2018 001 Effluent Chlorine, Total Residual 02/22/18 5 X week ug/I 28 43 53.6 Daily Maximum No Action, BPJ
Exceeded
04 - 2018 001 Effluent Chlorine, Total Residual 04/18/18 5 X week ug/I 28 36 28.6 Daily Maximum No Action, BPJ
Exceeded
05-2018 001 Effluent Chlorine, Total Residual 05/21/18 5 X week ug/I 28 45 60.7 Daily Maximum No Action, BPJ
Exceeded
06 - 2018 001 Effluent Chlorine, Total Residual 06/25/18 5 X week ug/I 28 49 75 Daily Maximum No Action, BPJ
Exceeded
02 - 2019 001 Effluent Chlorine, Total Residual 02/08/19 5 X week ug/I 28 41 46.4 Daily Maximum No Action, BPJ
Exceeded
02-2019 001 Effluent Chlorine, Total Residual 02/11/19 5 X week ug/I 28 38 35.7 Daily Maximum No Action, BPJ
Exceeded
06-2019 001 Effluent Chlorine, Total Residual 06/11/19 5 X week ug/I 28 47 67.9 Daily Maximum No Action, BPJ
Exceeded
08 - 2019 001 Effluent Chlorine, Total Residual 08/28/19 5 X week ug/I 28 47 67.9 Daily Maximum No Action, BPJ
Exceeded
09 - 2019 001 Effluent Chlorine, Total Residual 09/25/19 5 X week ug/I 28 30 7.1 Daily Maximum No Action, BPJ
Exceeded
02 - 2020 001 Effluent Chlorine, Total Residual 02/13/20 5 X week ug/I 28 32 14.3 Daily Maximum No Action, BPJ
Exceeded
03 - 2020 001 Effluent Chlorine, Total Residual 03/20/20 5 X week ug/I 28 45 60.7 Daily Maximum No Action, BPJ
Exceeded
08 - 2020 001 Effluent Chlorine, Total Residual 08/03/20 5 X week ug/I 28 44 57.1 Daily Maximum No Action, BPJ
Exceeded
08 - 2020 001 Effluent Chlorine, Total Residual 08/10/20 5 X week ug/I 28 33 17.9 Daily Maximum No Action, BPJ
Exceeded

MONITORING REPORT(MR) VIOLATIONS for:
Report Date: 04/22/21 Page 5 of 5
Permit: NC0006033 MRs Betweei 6 - 2016 and 4 - 2021
Facility Name: % Param Nam( %
Major Minor: %
Region: % Violation Category:% Program Category: %
County: % Subbasin:% Violation Action: %
PERMIT: NC0006033
FACILITY: City of Gastonia - Eagle Road WWTP
COUNTY: Gaston REGION: Mooresville
Limit Violation
MONITORING UNIT OF
OUTFALL LOCATION PARAMETER VIOLATION FREQUENCY
REPORT DATE MEASURE
LIMIT
CALCULATED
VALUE Over
VIOLATION TYPE VIOLATION ACTION
08-2020 001 Effluent Chlorine, Total Residual 08/11/20 5 X week ug/I 28 29 3.6 Daily Maximum No Action, BPJ
Exceeded
08 - 2020 001 Effluent Chlorine, Total Residual 08/12/20 5 X week ug/I 28 29 3.6 Daily Maximum No Action, BPJ
Exceeded
09 - 2020 001 Effluent Chlorine, Total Residual 09/02/20 5 X week ug/I 28 37 32.1 Daily Maximum No Action, BPJ
Exceeded
09 - 2020 001 Effluent Chlorine, Total Residual 09/03/20 5 X week ug/I 28 30 7.1 Daily Maximum No Action, BPJ
Exceeded
09 - 2020 001 Effluent Chlorine, Total Residual 09/22/20 5 X week ug/I 28 35 25 Daily Maximum No Action, BPJ
Exceeded
03 - 2021 001 Effluent Chlorine, Total Residual 03/10/21 5 X week ug/I 28 31 10.7 Daily Maximum No Action, BPJ
Exceeded
06-2017 001 Effluent pH 06/23/17 5 X week su 6 4.1 31.7 Daily Minimum Not Proceed to NOV
Reached
Monitoring Violation
MONITORING UNIT OF
OUTFALL LOCATION PARAMETER VIOLATION FREQUENCY
REPORT DATE MEASURE
LIMIT
CALCULATED
VALUE Over
VIOLATION TYPE VIOLATION ACTION
02 - 2020 001 Effluent Chlorine, Total Residual 02/08/20 5 X week ug/I Frequency Violation No Action, BPJ
02 - 2020 001 Effluent Oxygen, Dissolved (DO) 02/08/20 5 X week mg/I Frequency Violation No Action, BPJ
02 - 2020 001 Effluent pH 02/08/20 5 X week su Frequency Violation No Action, BPJ
02 - 2020 001 Effluent Temperature, Water Deg. 02/08/20 5 X week deg c Frequency Violation No Action, BPJ
Centigrade

Attachment A —Request for Missing Information
Table 2. EPA Application Form 2A Missing Information
40 CFR
122.21(j)(1)
1.1
Email address of facility contact [e-mail]
1.2
Applicant email address [e-mail]
1.3
Email address of the organization transporting the discharge for treatment prior to discharge
Not Applicable
1.4
Email address of the organization receiving the discharge for treatment prior to discharge
Not Applicable
1.5
Do you intend to request or renew one or more of the variances authorized at 40 CFR 122.21(n)? (Check all that apply. Consult
with your NPDES permitting authority to determine what information needs to be submitted and when.)
Discharges into marine waters (CWA Section Water quality related effluent limitation (CWA
301(h)) Section 302(b)(2))
x Not applicable
1.6
Email address of contractor responsible for operational or maintenance aspects of the treatment works
Not Applicable
40 CFR
122.21(j)(6)
1.7
Indicate the number of SIUs and NSCIUs that discharge to the POTW.
Number of SIUs
Number of ClUs
0
0
40 CFR
122.22(a) and (d)
1.8
Certification Statement
I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in
accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted.
Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the
information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that
there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing
violations.
Name (print or type first and last name)
Stephanie Scheringer
Official title
Division Manager Wastewater Treatment
Signature
Date signed
4/14/2021

TWOal I I I I \U TVERS I L I Ti E S
We are TRU to our customers!
June 18, 2020
Mr. Michael Montebello
North Carolina Division of Environmental Quality
1650 Mail Service Center
Raleigh, NC 27699-1617
RE: Industrial Waste Survey Summary: 5-Year Report
Dear Mr. Montebello:
The City of Gastonia Two Rivers Utilities Department (TRU) is required by NPDES Permit Part IV, C, 2 and
15A NCAC 2H .0905 to implement on -going waste survey activities and submit a summary of these activities
every 5 years. This report covers these activities for June 2015 to June 2020.
TRU uses the following methods to implement survey requirements to identify new and changed users:
monthly non-residential sewer connection listings, North Carolina Manufacturers Register, economic
development reports and status updates, Planning Commission meeting information, site plan submittals,
building permit listings, new business listings in the Gaston Gazette, and customer inquiries.
All industrial users identified as a potential source of discharge are evaluated by one or more of the following:
phone call, email, site visit, IWS form or permit application. For efficiency, customers are allowed to complete
IWS forms, scan and email them directly to Pretreatment Staff. All information is obtained and evaluated to
determine whether an SIU or Local Permit is required.
On -going efforts since 2015:
2016 — Four industrial users were sent an IWS and evaluated. No permits were necessary.
2017 — No industrial users required an IWS. The Town of Stanley was issued an SIU Permit and IBC
Specialties was issued an IU Permit.
2018 — Five industrial users were sent an IWS and evaluated. No permits were necessary.
2019 — Eight industrial users were sent an IWS and evaluated. Pharr was issued an SIU Permit.
2020 — Six industrial users were sent an IWS and evaluated. Permit evaluation is pending on four
industrial users.
Page 1 of 2

The 2019 North Carolina Manufacturers Register was reviewed and compared to the on -going IWS list.
Following this, TRU's IWS list contained 321 IUs for evaluation. All IUs that had not been evaluated since
the previous 5-year report, were re-evaluated in May and June of 2020 by one or more of the following
methods: checking the status in the billing database to determine a sewer connection, evaluating previous
IWS information, phone calls or emails to obtain more information, receiving a new IWS form, or
performing a site visit. There were 68 IUs that were found to either no longer be in business or did not have
a sewer connection. Staff made calls and emailed questions to 67 lUs that were determined to need further
evaluation and requested that 5 IUs re -submit an IWS.
Attached is a spreadsheet (See Attachment A) that reflects the activities that have occurred during the current
5-year reporting period of June 2015 through June 2020. As a result of the re-evaluation and site visits,
TRU will continue to proceed with permit evaluations for: The Rolling Door Co, Champion Powder
Coating, C&R Hard Chrome Services, Inc. and RWM Casters Company. These facilities currently have the
potential to be regulated as a CIU under 40 CFR 433 for chemical etching. The volume and concentration
are currently being determined. A full permit application was also requested from each industry.
The following is information regarding industrial users located within satellite jurisdictions that have a
bulk sewer connection with TRU:
• City of Bessemer City, City of Belmont, Town of Clover and City of Kings Mountain have
approved Pretreatment Programs and provide new IU information to TRU through on -going
communications and/or during annual inspections.
• The Town of Stanley became a TRU sewer customer in January 2016. A Pretreatment Program for
the town is administered by Two Rivers Utilities. In May 2018, the IWS submission for Stanley was
received and met the requirements by NC DEQ.
• The Towns of Lowell, Ranlo, McAdenville and High Shoals do not have any IUs listed on the 2019
NC Manufacturer's Register or any other IUs that discharge regulated process wastewater.
TRU currently has 25 SIUs and 4 local permits (See Attachment B). The following permits were either
new, rescinded or had name changes that occurred during the reporting period June 2015-June 2020:
1) Town of Ranlo, Cookson Co., Firestone, and Porters Fabrication permits were rescinded.
2) Town of Stanley, Pharr, and IBC Specialties are all new permits.
3) Colortex USA renamed to Altus Finishing.
4) Chemtura renamed to Lanxess.
5) Portajon of the Piedmont renamed to United Site Services.
6) Earth Farms renamed to Wind River Environmental, LLC dba Stanley Environmental.
7) Wix, Affina Corporation renamed to Mann + Hummel.
If you have any questions, please do not hesitate to contact me at 704-854-6672 or
[e-mail].
Sincerely,
coif_
Michael Alexander
Pretreatment Supervisor
Two Rivers Utilities
Page 2 of 2

2020 IWS Report - City of Gastonia
Attachment A
Industry Name
Check if No
Sewer
Service or
not in
Business
Date short
form
received
Date of
site visit
Evaluation Date
No process
flow
Approx.
Process or
other non -
domestic
flow(gpd)
Explanation of why SIU
permit is or isn't needed
C&R Hard Chrome Service, Inc.
6/12/2020
6/12/2020
6/12/2020
Permit Application and
sampling requested
Champion Powder Coating
6/9/2020
6/15/2020
6/9/2020
720
Permit Application and
sampling requested
R W M Casters Co.
6/2/2020
6/16/2020
6/16/2020
Permit Application and
sampling requested
The Rolling Doors Company LLC
10/24/2019
10/24/2019
< 100
CIU, but claims to
discharge < 100 gpd and
be NSCIU without need for
Permit. Have not
connected to sewer yet,
until approval
A.B. Carter, Inc.
5/6/2020
6,263
SIU Permit #1049, CIU 465
Altus Finishing LLC.
5/18/2020
6,138
SIU Permit #1060, POC for
Dyes
Bimbo Bakeries USA, Inc.
5/14/2020
5,095
SIU Permit #1056, Potential
POC discharger
CaroMont Regional Medical Center
5/6/2020
96,666
SIU Permit #1017, Hospital -
Large volume
Choice USA
5/15/2020
40,910
SIU Permit #1035, Beverages.
Process stopped 9/14/2019
Daimler Trucks North America, LLC
5/18/2020
22,285
SIU Permit #1023, CIU 433
Gaston County Landfill
5/6/2020
7,362
SIU Permit #1051, Landfill
Leachate
IBC Specialties
5/6/2020
6,567
IU Permit #2014, Potential
POC discharger
Industrial Electroplating
5/20/2020
39,957
SIU Permit #1011, CIU 433
and > 25,000 GPD
Industrial Fabricators
9/6/2011
5/20/2020
16,485
SIU Permit #1062, CIU 433
Industrial Glass Technologies
5/6/2020
587
IU Permit #3007, Hauled
Waste Permit
Evaluate with Permit App
Currently Permitted
1of11

2020 IWS Report - City of Gastonia
Attachment A
Check if No
Sewer
Service or
not in
Business
Date short
form
received
Date of
site visit
Evaluation Date
No process
flow
Approx.
Process or
other non -
domestic
flow(gpd)
Explanation of why SIU
permit is or isn't needed
Industry Name
Lanxess Solution, Inc.
5/21/2020
13,284
IU Permit #2008, Potential
POC discharger
Lubrizol Advanced Materials, Inc.
5/21/2020
16,723
SIU Permit #1053, CIU -
OCPSF
Mann+Hummel - Allen Plant
7/27/2011
5/21/2020
15,407
SIU Permit #1067, CIU 433
Modena Southern Dyeing Corporation
5/18/2020
13,345
SIU Permit #1032, Yarn and
Dyes- Large volume
OC Comp Non -Woven Tech (Owens Corning)
5/6/2020
163,547
SIU Permit #1068, > 25,000
GPD
Pharr
5/6/2020
45,143
SIU Permit #1071, > 25,000
GPD
Powder Coating Services, Inc.
5/6/2020
15,762
SIU Permit #1059, CIU 433
Regional Emergency Services Training Center (RESTC)
IU Permti #2012, Potential
Diesel fuel release
Stabilus
5/19/2020
21,536
SIU Permit #1021, CIU 433
Sunshine Uniform Services, Inc.
5/6/2020
30,109
SIU Permit #1013, > 25,000
GPD
United Site Services
5/18/2020
4,410
SIU Permit #1057, High POC
potential
Valley Proteins, Inc. Gastonia Division
5/21/2020
36,271
SIU Permit #1047, > 25,000
GPD
Water Supply & Treatment Division
5/6/2020
951,385
SIU Permit #1064, Large
volume
Wind River Environmental, LLC dba Stanley
Environmental (Earth Farms)
5/6/2020
51,933
SIU Permit #1066, > 25,000
GPD
Able Plating
X
7/7/2011
5/6/2020
No Potential Impact
ACCU-Spec Machine Products
8/4/2011
5/22/2020
X
No Process Flow
Acme Die & Machine Corp
7/21/2011
5/28/2020
X
No Process Flow
Action Demolition & Recycling
X
5/22/2020
No Sewer
Advance Auto Parts
7/11/2011
5/7/2020
X
No Process Flow
Advanced Machining Co. of Gastonia, Inc.
X
7/11/2011
5/7/2020
No Sewer
Affinia Group, Inc. Wix Filtration 1 Wix Way
5/7/2020
X
No Process Flow
Affinia Group, Inc. Wix Filtration 1525 S. Marietta Street
5/7/2020
X
No Process Flow
Currently Permitted
2 of 11

2020 IWS Report - City of Gastonia
Attachment A
Industry Name
Check if No
Sewer
Service or
not in
Business
Date short
form
received
Date of
site visit
Evaluation Date
No process
flow
Approx.
Process or
other non -
domestic
flow(gpd)
Explanation of why SIU
permit is or isn't needed
Aichele LLC.
8/19/2014
5/13/2020
—7
No Potential Impact
All American Braids, Inc.
7/18/2011
5/13/2020
X
No Process Flow
Alliance Machine & Fabrication, LLC.
3/23/2015
3/23/2015
6/2/2020
X
No Process Flow
American & Efird, Depot 21
7/18/2011
5/26/2020
X
No Process Flow
American & Efird, Plant 1 & 20
5/26/2020
X
No Process Flow
American & Efird, Plant 21
5/26/2020
X
No Process Flow
American & Efird, Plant 56
7/18/2011
5/26/2020
X
No Process Flow
American Forms MFG., INC.
5/13/2020
X
No Process Flow
American Linc, LLC
7/13/2011
5/26/2020
X
No Process Flow
Ames North America LLC
5/8/2019
5/9/2019
300
No Potential Impact
Atkinson International
9/7/2011
5/26/2020
X
No Process Flow
Atlantic Graphics
7/19/2011
5/13/2020
X
No Process Flow
Atrium Healthcare
6/17/2019
No Potential Impact
AZUSA International, INC.
5/26/2020
X
No Process Flow
Barkley Enterprises
7/11/2011
5/13/2020
X
No Process Flow
BAV Graphics
5/26/2020
X
No Process Flow
BCP
7/13/2011
5/13/2020
X
No Process Flow
BDI
9/19/2011
5/13/2020
X
No Process Flow
Beal Mfg, Inc.
7/7/2011
6/4/2020
X
No Process Flow
Belt Shop, Inc.
7/11/2011
5/14/2020
X
No Process Flow
Better Business Printing
5/14/2020
X
No Process Flow
Beveridge Machine Works, Inc
5/14/2020
No Potential Impact
Beverly Knits
X
7/27/2011
5/26/2020
No Potential Impact
Blue Devil Textile
9/1/2011
5/14/2020
X
No Process Flow
Blue Steel America
X
7/14/2011
5/26/2020
No Potential Impact
Bolin Mfg
X
7/11/2011
5/14/2020
No Potential Impact
Bowen Machine, Inc.
7/25/2011
5/14/2020
X
No Process Flow
Bradley Building Systems
8/2/2011
5/14/2020
X
No Process Flow
Breedlove Machine Co
X
7/13/2011
5/14/2020
No Potential Impact
Breedlove Mounts, Inc
X
5/14/2020
No Sewer
Brodin Landing Nets
X
8/19/2011
5/14/2020
No Sewer
Bruce's Iron & Metal
X
7/11/2011
5/14/2020
No Potential Impact
Burlan Corporation
8/10/2011
5/14/2020
X
No Process Flow
Burlan Manufacturing, LLC
6/15/2020
< 100
No Potential Impact
3 of 11

2020 IWS Report - City of Gastonia
Attachment A
Industry Name
Check if No
Sewer
Service or
not in
Business
Date short
form
received
Date of
site visit
Evaluation Date
No process
flow
Approx.
Process or
other non -
domestic
flow(gpd)
Explanation of why SIU
permit is or isn't needed
Burnett Machine Co, Inc.
7/11/2011
5/14/2020
X
No Process Flow
C.C. Dickson Co.
7/18/2011
5/14/2020
X
No Process Flow
Cabinet Co.
5/14/2020
X
No Process Flow
Capezio, Inc.
7/13/2011
5/14/2020
X
No Process Flow
Carolina Brush Mfg. Co., Inc.
5/27/2020
X
No Process Flow
Carolina Custon Millwork
5/14/2020
No Potential Impact
Carolina Floral
X
7/14/2011
5/14/2020
No Potential Impact
Carolina Industrial Foundry
X
9/20/2011
5/14/2020
No Sewer
Carolina Warp Prints Inc.
X
5/27/2020
No Sewer
Carolinas Telco Federal Credit Union
7/14/2011
5/14/2020
X
No Process Flow
Carson Machine Co
8/19/2011
5/14/2020
X
No Process Flow
Cavendish Brewery Company
8/16/2016
8/16/2016
8/16/2016
No Potential Impact
Cemex Construction Materials, LP
X
7/11/2011
5/14/2020
No Sewer
Centerline Precision Machining, Inc.
7/11/2011
5/14/2020
X
No Process Flow
Century Building Products
7/11/2011
5/14/2020
X
No Process Flow
Chambers Container
7/15/2011
5/14/2020
X
No Process Flow
Champion Thread Co.
5/14/2020
X
No Process Flow
Chemtura Corp. (see Lanxess)
5/15/2020
Name Change
City Fire and Safety
7/15/2011
5/15/2020
X
No Process Flow
Cline Complany,Inc., D.E.
X
7/25/2011
5/15/2020
No Potential Impact
CMC Steel Fabricators, Inc.
7/14/2011
6/4/2020
X
No Process Flow
Coats HP, Inc - 9-23 Plant
2/7/2020
2/7/2020
X
No Process Flow
Coats HP, Inc - 185 Plant
2/7/2020
2/7/2020
X
No Process Flow
Collins Fabrication & Welding, LLC
8/2/2011
5/18/2020
X
No Process Flow
Color Mate Inc.
X
9/20/2011
5/27/2020
No Sewer
Colortex, USA (see Altus)
X
5/18/2020
No Sewer
Concept Steel, Inc.
7/13/2011
5/27/2020
X
No Process Flow
Conitex-Sonoco U.S.A., Inc.
7/14/2011
5/27/2020
X
No Process Flow
Consolidated Textile Service, Inc.
7/14/2011
5/18/2020
X
No Process Flow
Control Source
7/29/2011
5/18/2020
X
No Process Flow
Cookson Co., Inc.
5/18/2020
624
Previous Permit #1065
Cougar, Inc.
9/7/2018
9/7/2018
X
No Process flow
CR Miles Textile Parts Co.
X
9/20/2011
5/18/2020
No Sewer
Creative Ticking
5/27/2020
No Potential Impact
4 of 11

2020 IWS Report - City of Gastonia
Attachment A
Industry Name
Check if No
Sewer
Service or
not in
Business
Date short
form
received
Date of
site visit
Evaluation Date
No process
flow
Approx.
Process or
other non -
domestic
flow(gpd)
Explanation of why SIU
permit is or isn't needed
Crisp Printers, INC.
5/18/2020
X
No Process Flow
CS Alloys
3/23/2015
5/18/2020
X
No Process Flow
Curtiss-Wright Controls
5/18/2011
7/31/2015
5/18/2020
X
No Process Flow
Custom Marking & Printing
5/18/2020
X
No Process Flow
Cutting Edge Fabrication
7/18/2011
5/18/2020
X
No Process Flow
D Block Metal, LLC
5/13/2013
5/27/2020
X
No Process Flow
Dallas Machine Co., Inc.
X
8/2/2011
5/18/2020
X
No Sewer
Dalton Dynamics Corp.
6/11/2015
4/7/2016
5/18/2020
X
No Process Flow
Danner Machine & Fabrication
X
8/2/2011
5/19/2020
No Sewer
Davis Machine
X
7/13/2011
5/19/2020
No Potential Impact
Dennis Machine Works
X
9/20/2011
5/19/2020
No Sewer
Design & Mfg
7/14/2011
5/19/2020
X
No Process Flow
Digitrol, Inc.
7/14/2011
5/19/2020
X
No Process Flow
Dixie Glass Co.
X
7/18/2011
5/19/2020
No Potential Impact
Dixon Quick Coupling
5/22/2020
No Potential Impact
Dramar Machine Devices
6/8/2015
6/15/2020
6/15/2020
No Potential Impact
Dynamic Stampings of NC, Inc.
7/14/2011
6/2/2020
X
No Process Flow
Econo Gutter & Siding
9/20/2011
5/19/2020
X
No Process Flow
EFF Plastics
X
7/14/2011
5/19/2020
X
No Process Flow
Envirovision Technologies, LLC
5/27/2020
No Potential Impact
Fab-Tec, Inc.
X
7/18/2011
5/19/2020
X
No Process Flow
Facet Foundry Jewelry Studio
5/19/2020
X
No Process Flow
FAIST Chemtec, Inc.
6/8/2015
6/4/2020
X
50
No Process Flow
Faith Regional Prosthetics & Orthotics Center
5/19/2020
X
No Process Flow
Fastenal Co.
7/18/2011
5/19/2020
X
No Process Flow
Ferguson Enterprises, Inc.
7/14/2011
5/19/2020
X
No Process Flow
Fidelity Assoc
7/14/2011
5/19/2020
X
No Process Flow
Finestra (and Rowley)
X
7/20/2011
5/19/2020
No Potential Impact
Foss Recycling, Inc
5/19/2020
No Potenital Impact
French Apron & Mfg
7/20/2011
5/27/2020
X
No Process Flow
G&S Co. Inc.
X
9/20/2011
5/20/2020
No Sewer
Gaddis Group, LLC
5/20/2020
X
No Process Flow
Gamco Service, Inc.
X
7/20/2011
5/20/2020
X
No Process Flow
Gastex
X
5/20/2020
No Potential Impact
5 of 11

2020 IWS Report - City of Gastonia
Attachment A
Industry Name
Check if No
Sewer
Service or
not in
Business
Date short
form
received
Date of
site visit
Evaluation Date
No process
flow
Approx.
Process or
other non -
domestic
flow(gpd)
Explanation of why SIU
permit is or isn't needed
Gaston Gazette
7/15/2011
5/20/2020
X
No Process Flow
Gaston Regional Prosthetics Orthotics Center
7/21/2011
5/20/2020
X
No Process Flow
Gaston Skills, Inc.
7/20/2011
5/20/2020
X
No Process Flow
Gastonia Industrial Truck
X
7/25/2011
5/20/2020
No Potential Impact
Gastonia Sheet Metal Works, Inc.
9/20/2011
5/20/2020
X
No Process Flow
Geiger Automotive USA, Inc.
5/20/2020
X
No Process Flow
General Projects, Inc.
X
7/20/2011
5/20/2020
X
No Process Flow
Gentry Plastics
4/14/2020
4/14/2020
X
No Process Flow
Glenn Printing Co., Inc.
5/20/2020
X
No Process Flow
Goodwill Publishers
7/18/2011
5/20/2020
X
No Process Flow
Gray Industrial Steam LTD
X
7/25/2011
5/20/2020
X
No Process Flow
Grifols
7/2/2019
No Potential Impact
Hagan Kennington Oil Co.
5/20/2020
X
No Process Flow
Hamilton Drywall/Carolina Pacific
6/21/2019
6/21/2019
No Potential Impact
Hanger Clinic
5/20/2020
No Potential Impact
Harris Machine Parts
X
7/29/2011
5/20/2020
No Sewer
Heatherlock Textiles Inc.
10/13/2014
5/20/2020
X
No Process Flow
Henry Fibers, Inc.
7/15/2011
5/20/2020
X
No Process Flow
Herman Reeves Sheet Metal, Inc.
7/20/2011
5/20/2020
X
No Process Flow
Hester Enterprises, Inc.
X
7/25/2011
5/20/2020
No Potential Impact
Holland -Tanner Machine Works, Inc.
7/15/2011
5/20/2020
X
No Process Flow
Holzma U.S., Inc.
X
7/20/2011
5/20/2020
No Sewer
Hoover, Inc. D.R.
5/20/2020
X
No Process Flow
Humphrey Pattern Works
7/15/2011
5/20/2020
X
No Process Flow
Humphries Textile Parts, Inc.
X
9/20/2011
5/20/2020
No Sewer
IMACC Corp
7/20/2011
3/18/2019
5/27/2020
X
No Process Flow
Image 360
5/20/2020
No Potential Impact
lmagemark Business Services, Inc
5/20/2020
No potential Impact
Imperial Machine Co., Inc.
X
9/19/2011
5/20/2020
No Sewer
Independent Casting & Jewelry Repair
10/7/2016
5/20/2020
X
No Process Flow
Industrial Metal Craft, Inc.
4/13/2015
4/13/2015
5/20/2020
X
No Process Flow
Inweld Alloys and Supplies
9/19/2011
5/20/2020
X
No Process Flow
J&D Enterprise Inc.
5/20/2020
X
No Process Flow
J&D Plating, Inc.
9/19/2011
5/20/2020
X
No Process Flow
6 of 11

2020 IWS Report - City of Gastonia
Attachment A
Industry Name
Check if No
Sewer
Service or
not in
Business
Date short
form
received
Date of
site visit
Evaluation Date
No process
flow
Approx.
Process or
other non -
domestic
flow(gpd)
Explanation of why SIU
permit is or isn't needed
J&F Heat Treating Inc.
6/4/2015
5/27/2020
X
No Process Flow
J&P Enterprises, Inc.
X
6/4/2015
5/20/2020
No Potential Impact
Jana's Sign Designs & Lettering
X
5/20/2020
X
No Process Flow
Janki Khyati, Inc.
X
5/20/2020
X
No Process Flow
JL&S Woodworking
7/20/2011
5/20/2020
X
No Process Flow
JStanton Enterprises, Inc.
7/19/2011
5/20/2020
X
No Process Flow
K B Parts
5/20/2020
X
No Process Flow
Kamdar Industries International
X
5/20/2020
No Potential Impact
Killingsworth Inc.
X
7/18/2011
5/21/2020
X
No Process Flow
Kiser -Harris Distribution
X
12/2/2019
X
No Process Flow
KMS, Inc.
5/20/2020
No Potential Impact
Koops Woodworks, LLC
X
7/19/2011
5/21/2020
X
No Process Flow
Krispy Kreme Doughnut Corp.
7/20/2011
6/3/2020
X
No Process Flow
L & R Specialties, Inc.
7/21/2011
5/21/2020
X
No Process Flow
L&L Machine Co., Inc.
X
7/18/2011
5/21/2020
No Potential Impact
Lee & Co., W.D.
7/18/2011
5/27/2020
X
No Process Flow
Liberty Oak, Inc
1/19/2018
No Potential Impact
Lit Industries, Inc.
7/27/2011
5/21/2020
X
No Process Flow
Loveday Lumber Co. Inc.
5/21/2020
X
No Process Flow
Loyal Systems
1/10/2020
1/10/2020
No Potential Impact
Lucite Plus Inc.
5/21/2020
X
No Process Flow
M&M Electric Service, Inc.
7/27/2011
5/21/2020
X
No Process Flow
M&M Machinery Sales, LLC
8/2/2011
5/21/2020
X
No Process Flow
M&R Machine Tooling, Inc.
5/21/2020
X
No Process Flow
M&R Machine Tooling, Inc.
5/21/2020
No Potential Impact
Mann+Hummel Filtration Technology U.S. LLC
X
5/21/2020
No Sewer
Mann+Hummel Filtration Technology U.S. LLC (HQ)
X
5/21/2020
No Sewer
Marc Machine Works, Inc.
X
7/29/2011
5/21/2020
No Sewer
MedWaste Solution LLC
3/23/2012
5/21/2020
2,000
No Potential Impact
Meridian Speciality Yarn Group, Inc.
8/2/2011
5/21/2020
X
No Potential Impact
Metal Recycling Services
5/21/2020
No Potential Impact
Metro Associates
7/19/2011
5/21/2020
X
No Process Flow
Metro Branch, Inc.
5/21/2020
X
No Process Flow
Metro Screen, Inc.
9/19/2011
5/21/2020
X
No Process Flow
7 of 11

2020 IWS Report - City of Gastonia
Attachment A
Industry Name
Check if No
Sewer
Service or
not in
Business
Date short
form
received
Date of
site visit
Evaluation Date
No process
flow
Approx.
Process or
other non -
domestic
flow(gpd)
Explanation of why SIU
permit is or isn't needed
Metrolina Gear & Machine, Inc.
X
5/21/2020
No Potential Impact
Miira Entrprises, LLC
7/27/2011
5/21/2020
X
No Process Flow
Mik-All Machine Co., Inc.
7/27/2011
5/21/2020
X
No Process Flow
Mik-All Metal Treating
7/29/2011
5/21/2020
X
No Process Flow
Milanco Chemical Inc.
7/29/2011
7/31/2015
5/21/2020
10
No Potential Impact
Minges Printing & Advertising, Inc.
5/21/2020
X
No Process Flow
Mitcham & Co., Inc.
5/21/2020
X
No Process Flow
Motor Shop
8/2/2011
5/11/2020
X
No Process Flow
Mountain Oak Millwork, LLC
10/8/2018
10/8/2018
X
No Process Flow
Mt. Olive Pickle Co.
9/20/2011
5/11/2020
X
No Process Flow
Multipli Machinery
X
8/2/2011
5/11/2020
X
No Process Flow
National Roller Supply, Inc.
7/29/2011
6/3/2020
No Potential Impact
Newcomb Spring of North Carolina
6/8/2020
6/8/2020
No Potential Impact
Nolen Machine Co.
X
8/2/2011
5/11/2020
No Sewer
Nussbaum Automotive Solutions
5/27/2020
X
No Process flow
Oreck Floor Care
X
9/20/2011
5/6/2020
No Potential Impact
PACOR, Inc.
6/4/2020
X
No Process Flow
Park Mfg, Co., Inc.
X
7/21/2011
5/6/2020
No potential impact
Parkdale America, LLC/Parkdale Mills
7/21/2011
5/27/2020
No Potential Impact
Parker D. Fence Co.
5/6/2020
X
No Process Flow
Parts Cleaning Technologies
4/1/2020
X
No Potential Impact
Patterson Machine Service, Inc.
7/29/2011
5/6/2020
No Process flow
Petty Machine Co.
X
8/2/2011
5/27/2020
No Sewer
PHC Industrial
5/27/2020
X
No Process Flow
Piedmont Pump & Valve
X
8/2/2011
5/6/2020
X
No Process Flow
Pioneer Machine Works
5/6/2020
X
No Process Flow
Porter's Enterprises, Inc.
5/6/2020
X
No Process Flow
Pratt (Triad Industries), LLC
5/15/2020
No potential impact
Precision Comb Works, Inc.
7/21/2011
5/15/2020
X
No Process Flow
Precision Machine Products, Inc.
7/21/2011
5/27/2020
X
No Process Flow
Precision Tool & Dye
5/15/2020
X
No Process Flow
Premier Logistics, Inc.
5/27/2020
X
No Process Flow
Premier Sports Lighting, LLC
1/19/2018
4/1/2020
X
No Potential Impact
Proto Stitch Wizard, Inc. (american metal fab)
7/18/2011
5/15/2020
X
No Process Flow
8 of 11

2020 IWS Report - City of Gastonia
Attachment A
Industry Name
Check if No
Sewer
Service or
not in
Business
Date short
form
received
Date of
site visit
Evaluation Date
No process
flow
Approx.
Process or
other non -
domestic
flow(gpd)
Explanation of why SIU
permit is or isn't needed
Prototype Tooling Co.
7/19/2011
5/15/2020
X
No Process Flow
Quick Vac, Inc.
8/2/2011
5/15/2020
X
No Process Flow
Quiknit Crafting
8/2/2011
6/4/2020
X
No Process Flow
Quinn's Textile Service
7/29/2011
5/15/2020
X
No Process Flow
RABB, Inc., C. L.
X
8/1/2011
5/15/2020
No Sewer
Rags Unlimited
7/28/2011
5/27/2020
X
No Process Flow
Rahmann Belting & Industrial Rubber Products, Inc.
7/18/2011
5/18/2020
X
No Process Flow
Rainbow Printing Co.
5/15/2020
X
No Process Flow
Red Valve Co., Inc.
7/28/2011
5/27/2020
X
No Process Flow
Reddy Ice Corp.
7/18/2011
5/18/2020
X
No Process Flow
Reel -Tex Inc.
X
8/2/2011
5/18/2020
No Sewer
REM Enterprises
8/2/2011
5/15/2020
X
No Process Flow
Repi LLC
5/27/2020
X
No Process Flow
Roechling Engineered Plastics
5/22/2020
No Potential Impact
Rowley CO.
5/27/2020
No Potential Impact
Saco Machine, Inc.
X
7/21/2011
5/18/2020
No Sewer
Sans Technical Fibers, LLC
X
5/18/2020
No Sewer
Schwartz Steel Service, Inc.
6/2/2020
X
No Process Flow
Scivolutions, Inc.
4/2/2013
5/18/2020
X
No Process Flow
Scrub Up
8/2/2011
5/18/2020
X
No Process Flow
Serafini, Inc. RA
9/20/2011
3/23/2015
5/19/2020
X
No Process Flow
Servtek
X
8/19/2011
5/19/2020
No Sewer
Shreya Corporation
X
8/2/2011
5/19/2020
No Sewer
Sign Connection, Inc.
5/19/2020
X
No Process Flow
Signs Now
8/2/2011
5/19/2020
X
No Process Flow
Sisco Fire & Safety
7/18/2011
5/19/2020
X
No Process Flow
Southeast Electrical Systems
8/2/2011
5/27/2020
X
No Potential Impact
Southern Breeze Paper
X
7/21/2011
5/19/2020
No Sewer
Southern States Co -Op, Inc.
8/2/2011
5/19/2020
X
No Process Flow
Speciality Machine Co., Inc.
8/2/2011
5/19/2020
X
No Process Flow
Speedi Sign
8/2/2011
5/19/2020
X
No Process Flow
Speedwell Machine Work
X
5/19/2020
No Sewer
State Line Scrap Metal
8/2/2011
5/19/2020
X
No Process Flow
Sterling Machine Works
X
8/2/2011
5/19/2020
No Sewer
9 of 11

2020 IWS Report - City of Gastonia
Attachment A
Industry Name
Check if No
Sewer
Service or
not in
Business
Date short
form
received
Date of
site visit
Evaluation Date
No process
flow
Approx.
Process or
other non -
domestic
flow(gpd)
Explanation of why SIU
permit is or isn't needed
Sterling Rack Inc.
4/9/2015
5/28/2020
X
No Process Flow
Stewart Gear Manufacturing, Inc.
8/4/2011
5/28/2020
X
No Process Flow
Stowe Timber and Pallet
X
8/4/2011
6/10/2020
No Sewer
Stowe Timber Co. (fka stowe timber and pallet)
X
7/29/2011
6/4/2020
No Sewer
Subtle Impressions, Inc.
6/5/2015
5/20/2020
150
No Potential Impact
Superior Pastics, Inc.
6/4/2020
X
No Process Flow
TAIG
11/7/2011
5/20/2020
X
No Process Flow
Tallent Drum Company
7/21/2011
6/12/2020
6/15/2020
No Potential Impact
Tamrod's Screen Printing
5/20/2020
X
No Process Flow
TCI Machinery, Inc. (TCI Mobility listed on register list?)
9/20/2011
6/2/2020
X
No Process Flow
TCI Supply, Inc.
5/20/2020
X
No Process Flow
Testa Laundry (now called Tops Wash)
7/21/2011
5/20/2020
X
No Process Flow
Texlon Plastics Corp
4/30/2015
5/20/2020
X
No Process Flow
Textile Parts & Machine, Inc.
8/4/2011
5/28/2020
X
No Process Flow
Thomas Concrete
X
7/29/2011
5/20/2020
No Sewer
Titan Fabrication, Inc.
7/27/2011
5/20/2020
X
No Process Flow
Tony's Ice Cream Co., Inc.
7/18/2011
5/20/2020
No Potential Impact
Tool & Mold Works
7/21/2011
5/21/2020
X
No Process Flow
Total Packaging Co. Inc.
11/18/2013
5/20/2020
X
No Process Flow
Trac Plastics
9/20/2011
3/25/2015
5/27/2020
X
No Process Flow
Triad Packing Design & Display
5/21/2020
X
No Process Flow
Tricon Technologies
3/29/2016
3/29/2016
X
No Process Flow
Tri-State Plastics, Inc.
8/4/2011
5/21/2020
X
No Process Flow
Tullent Drum
7/21/2011
5/21/2020
X
No Process Flow
U.S. Soft Wiping Cloth, Inc.
5/21/2020
X
No Process Flow
United Oil of the Carolinas, Inc.
8/4/2011
5/21/2020
X
No Process Flow
Universal Black Oxide
8/4/2011
7/30/2015
5/28/2020
X
No Process Flow
Wayne Machine Company
X
9/19/2011
5/21/2020
No Sewer
Weldcote Metals, Inc.
X
9/19/2011
5/21/2020
No Sewer
Wilbert Plastic Services
7/29/2011
5/21/2020
X
No Process Flow
Wilson Collision Center
7/2/2019
7/2/2019
X
No Process Flow
Wirewise, Inc.
7/21/2011
5/21/2020
X
No Process Flow
Witten Automatic Vent Co., Inc.
7/21/2011
5/27/2020
X
No Process Flow
WNC Tool & Die
9/19/2011
3/25/2015
5/27/2020
X
No Potential Impact
10 of 11

2020 IWS Report - City of Gastonia
Attachment A
Industry Name
Check if No
Sewer
Service or
not in
Business
Date short
form
received
Date of
site visit
Evaluation Date
No process
flow
Approx.
Process or
other non -
domestic
flow(gpd)
Explanation of why SIU
permit is or isn't needed
Wood Creations
9/20/2011
5/21/2020
X
No Process Flow
Wood Finishers Supply
7/27/2011
5/21/2020
X
No Process Flow
WP Turner Plumbing Co. Inc.
5/13/2015
5/21/2020
X
No Process Flow
Wyant & Son Monuments, Inc.
7/27/2011
5/21/2020
X
No Process Flow
Xtreme Metal Finishing
8/26/2011
5/21/2020
X
No Process Flow
Yardsigns
5/27/2020
X
No Process Flow
Yarntex CORP
5/21/2020
X
No Process Flow
Zodiac Phish, LLC
9/19/2011
5/21/2020
X
No Process Flow
11 of 11

Attachment B
Two Rivers Utilities
Permitted Industrial Users
Industry Name
Facility Address
Permit #
Classification
AB Carter
4801 York Highway
1049
CIU
Daimler Trucks, North America
1400 Tulip Dr
1023
CIU
Industrial Electroplating Co.
317 S. Linwood Rd
1011
CIU
Industrial Fabricators
4328 South York Hwy
1062
CIU
Lubrizol Advanced Materials, Inc.
207 Telegraph Dr
1053
CIU
MANN+HUMMEL
2900 Northwest Blvd
1067
CIU
Powder Coating Services, Inc.
1260 Shannon Bradley Rd
1059
CIU
Stabilus
1201 Tulip Dr
1021
CIU
Altus Finishing
1711 Sparta Ct
1070
SIU
Bimbo Bakeries
1029 Cox Rd
1056
SIU
CaroMont Health
2525 Court Dr
1017
SIU
Choice USA Beverages, Inc.
809 East Franklin Blvd
1035
SIU
City of Bessemer City
132 W. Virginia Ave
1055
SIU
City of Kings Mountain
1013 North Piedmont Ave
1027
SIU
Wind Rivers Environmental, LLC.
351 Colt Thornburg Rd
1066
SIU
Gaston County Landfill
3155 Philadelphia Church Rd
1051
SIU
Modena Southern Dyeing Corp.
1004 East Long Ave
1032
SIU
Owens Corning, Inc.
1230 Gastonia Technology Pkwy
1068
SIU
Pharr
100 Main St, McAdenville
1071
SIU
Sunshine Uniform Service, Inc.
1110 Jenkins Rd
1013
SIU
Town of Clover
114 Bethel St
1048
SIU
Town of Stanley
114 South Main St
1069
SIU
United Site Services
212 Bulb Ave
1057
SIU
Valley Proteins Gastonia Division
5533 South York Rd
1047
SIU
Water Supply & Treatment
250 Long Ave
1064
SIU
IBC Specialties
101 Boxwood Ln
2014
IU
Industrial Glass Technologies
112 Superior Stainless Rd
3007
IU
LanXess Solutions Inc.
214 West Ruby Ave
2008
IU
RESTC
201 South Hwy 321
2012
IU
1 of 1

•
TWNLVERS
ILITIES
We are TR U to our customers!
May 8, 2018
Mr. Mike Templeton
Wastewater Permitting Section
Department of Environmental Quality/DWR
1617 Mail Service Center
Raleigh, NC 27699-1617
P
TWO RIVERS 4_JTILITIES (TRU)
P.O. Box 1748
Gastonia, NC 28053-1748
irnfoctwionver•utilitie5.com
tiversutllities.com
RE: Request for Revision to NPDES Permit NC0006033 to Add Supplemental Nutrient Allocation
Dear Mr. Templeton:
As has previously been discussed, the City of Gastonia requests that NPDES Permit NC0006033 (Eagle Road
Wastewater Treatment Plant) be modified to include supplemental nutrient allocation that the City of Gastonia
is purchasing from Lowell Investments I, LLC (NPDES Permit NC0005274).
The City of Gastonia and Lowell Investments I, LLC have entered into an agreement on December 27, 2017 for
the purchase of Lowell Investment I, LLC's total allocation of 144 Ibs/day of total nitrogen and 7.6 Ibs/day of
total phosphorus. An executed copy of this agreement is attached.
Per earlier discussions, our understanding is that this allocation can be added to permit NC0006033 by listing it
in as supplemental allocation. We understand this allocation would not become part of the active allocation
until there is an expansion of the flow limit for the facility.
Also from our earlier discussions, we understand that this revision will be considered a "Major Permit
Modification" and therefore have included a check to NCDEQ for the amount of $1,030.00 to cover this fee.
We appreciate DEQ's assistance with this permit request. Please let us know if there is anything additional
needed from us to complete this request.
Sincerely,
Stephanie Scheringer
Division Manager Wastewater Treatment
cc: Mr. David Shellenbarger, Assistant WWTD Manager Compliance
Enclosures: Purchase Contract between City of Gastonia and Lowell Investments I, LLC
Check # 134793 to NCDEQ
Certified Mail: 7014 0150 0002 0276 0913

os,eI goc'1
STATE OF NORTH CAROLINA
COUNTY OF GASTON
PURCHASE CONTRACT
THIS PURCHASE CONTRACT (hereinafter referred to a "Contract"), entered into this
2. 7 +A\ day of Oc,. , 2017, by and between LOWELL INVESTMENTS I,
LLC, hereinafter referred to as the "Seller"; and CITY OF GASTONIA, a North Carolina
Municipal Corporation, hereinafter referred to as "Buyer";
WITNESSETH:
WHEREAS, Seller is the owner of a nutrient discharge allocation under the Lake Wylie
TMDL 1995 Catawba River Basin Wide Water Quality Management Plan consisting of 144
lbs/day of Total Nitrogen and 7.6 lbs/day of Total Phosphorus (the "Total Allocation") as
evidenced by NPDES Permit #NC0005274; and,
WHEREAS, Seller's NPDES Permit is scheduled to be terminated in early 2018; and,
WHEREAS, the Total Allocation will be eliminated upon the termination of Seller's
NPDES Permit unless the Total Allocation is transferred to another active NPDES Permit; and,
WHEREAS, the North Carolina Division of Water Resources of the Department of
Environmental Quality has acknowledged that the Total Allocation can be transferred from
Seller's NPDES Permit #NC0005274 to be held in reserve for Buyer's NPDES Permit
#NC0020184 until such time as the Total Allocation would need to be activated by Buyer in order
to accommodate an increase in the nutrient limits currently approved for Buyer's NPDES Permit,
as evidenced by a letter from Michael E. Templeton, P.E. dated NOvQ\o -' \y , 2017,
attached hereto and incorporated herein by reference; and,
WHEREAS, Buyer has no immediate need to increase Buyer's nutrient limits; however,
Buyer has determined that it would be in the best interest of its utility service rate payers to acquire
the Total Allocation to be held in reserve until such time as Buyer realizes a need to increase
Buyer's nutrient limits; and,
WHEREAS, Buyer and Seller have agreed that it would be in their mutual best interests to
enter into an agreement whereby the elimination of the Total Allocation will be avoided by
transferring the Total Allocation to be held in reserve under Buyer's NPDES Permit, with Buyer
having the option to activate the Total Allocation for Buyer's use at such time as Buyer requires
an increase in Buyer's nutrient limits under Buyer's NPDES Permit;
NOW, THEREFORE, in consideration of the foregoing recitals, the mutual promises and
covenants contained herein, and the payments from Buyer to Seller referred to below, the receipt
and sufficiency of which are hereby acknowledged, the Buyer and Seller agree as follows:
Agree1560

1. Purchase. Subject to the terms hereof and in consideration of the sum of two thousand dollars
($2,000.00) paid by Buyer to Seller (the "Option Money"), Seller hereby sells to Buyer the Total
Allocation for the sole purpose of having the Total Allocation held in reserve under Buyer's
NPDES Permit.
2. Option to Activate the Total Allocation. In further consideration of the payment of the Option
Money, Buyer hereby grants to Seller the exclusive option to obtain from the State of North
Carolina an activation of the Total Allocation as part of the nutrient limits Buyer is permitted to
discharge under Buyer's NPDES Permit (hereinafter the "Option"). The period during which
Buyer may exercise the Option shall commence upon the date of execution of this Purchase
Contract and shall continue and exist for a period of fifteen (15) years (the "Option Period"). The
Option Period may be extended by Buyer for two additional five (5) year Option Periods by
providing Seller with written notice of Buyer's intent to extend the Option Period at least 30 days
prior to the expiration of the then current Option Period.
3. Transfer of Total Allocation During Option Period. Upon execution of this Purchase
Contract, Buyer and Seller shall jointly file a request with the North Carolina Wastewater
Permitting Section of the Division of Water Resources of the Department of Environmental
Quality to modify their respective NPDES Permits in order to transfer the Total Allocation under
Seller's permit to Buyer's permit to be held as reserved allocation for Buyer's permit bubble limit
during the Option Period. In the event that the transfer of the Total Allocation is not approved or
cannot be accomplished for any reason, then this agreement shall terminate and Buyer shall be
entitled to a full refund of the Option Money. In the event that the transfer of the Total Allocation
is approved and accomplished but Buyer fails to exercise its option to activate the Total Allocation
during the Option Period, or any extension thereof, Buyer's right to activate the Total Allocation
shall terminate.
4. Exercise of Option. At any time during the Option Period, or any extension thereof, Buyer
may exercise its option to activate the Total Allocation by written notice personally delivered to
the Seller or deposited in the United States Mail, postage prepaid, registered or certified mail,
return receipt requested, addressed to Seller at the notice address contained herein, or such other
notice address as Seller may provide Buyer in writing after the initial execution of this agreement.
5. Additional Consideration Due Seller Upon Exercise of Option. Upon exercise of the Option
by Buyer during the Option Period, or any extension thereof, the terms and conditions of such
activation shall be as follows:
(A) Additional Cash Payment. The Additional Cash Payment due Seller for the activation of
the Total Allocation by Buyer shall be two hundred thousand dollars ($200,000.00), payable to
Seller at closing. In the event that Buyer does not exercise the Option within five (5) years from
the date of execution of this Purchase Agreement, the amount of the Additional Cash Payment
shall increase by a percentage equal to the percentage increase in the Consumer Price Index, if
any, during that time period between five years from the date of execution of this Purchase
Agreement and the date that the Option is exercised by Buyer. Provided, however, that in no event
shall the Additional Cash Payment exceed $ 2S0.3 0 00 . Q Q
Agreel560

(B) Closing. Upon exercise of the Option Buyer shall immediately request from the appropriate
North Carolina regulatory authority written confirmation that the Total Allocation can and has
been transferred to Buyer's NPDES permit and activated such that Buyer may increase Buyer's
nutrient limits by an amount equal to the Total Allocation. The closing and payment of the
Additional Cash Payment shall occur at the offices of the Buyer or at such other place in Gaston
County, North Carolina as may be determined mutually by Buyer and Seller within ninety (90)
days of receipt of written confirmation from the appropriate North Carolina regulatory authority
that the Total Allocation has been permanently transferred to Buyer's NPDES permit and
activated. The parties shall also execute and deliver at closing any other documents reasonably
identified by Buyer and Seller as necessary or appropriate to complete and evidence the transaction
contemplated hereby.
(C) Conditions Precedent. The obligations and liabilities of the Buyer and Seller hereunder shall
be in all respects conditioned upon satisfaction of each of the following conditions precedent. The
failure of any condition precedent, unless waived, shall entitle either party, in addition to its other
rights and remedies provided in this Purchase Contract, if any, to terminate this Purchase Contract
on or before the Closing Date and upon such termination due to the failure of Seller to be able to
complete the transaction, Buyer shall be entitled to a return of the Option Money. Termination by
Seller due to Buyer's failure to be able to complete the transaction shall entitle Seller to retain the
Option Money as liquidated damages.
(i) Authorizations and Approvals. The Buyer shall have obtained the regulatory approval
and Buyer shall have obtained assurances to its reasonable satisfaction that Seller has the requisite
legal authority to complete the transaction contemplated herein. The Seller shall be satisfied as to
the content and scope of Buyer's regulatory approval and that Buyer has the requisite legal
authority to complete the transaction contemplated herein.
(ii) No Change in Seller's Total Allocation. Seller shall hold and be able to transfer
and/or Buyer shall be able to activate the entire Total Allocation offered. If, at the time of exercise
of the Option, Seller does not hold or is not able to transfer, or Buyer is not able to activate, the
entire Total Allocation offered, Buyer shall have the option, in Buyer's sole discretion, to either
terminate this Contract and receive a full refund of the Option Money; or, to proceed to closing
and purchase any smaller portion of the Total Allocation offered that Seller then holds and is able
to transfer and/or Buyer is able to activate with the Additional Cash Payment being reduced by a
percentage equal to the percentage by which the Total Allocation has been reduced.
(iii) Change in Laws. There shall have been no change in statutes or regulations and no
administrative or legal decision or opinion by any court or any administrative agency materially
affecting Buyer's ability to acquire, hold, activate and use the Total Allocation offered by Seller
for the purposes described herein, or affecting Seller's ability to transfer the Total Allocation
offered.
(iv) Accuracy of Representations and Warranties. All representations and warranties
made by Buyer and Seller in this Contract shall be true and accurate in all material respects.
Agree1560

(v) Change in or Elimination of the Lake Wylie TMDL. There shall be no change in
the Lake Wylie TMDL, which would eliminate all or a portion of the Total Allocation, or prevent
Buyer from activating all or a portion of the Total Allocation. Any such change in the Lake Wylie
TMDL shall entitle Buyer to terminate this Purchase Contract with no further obligations or duties
to Seller.
(D) Representations and Warranties of Seller. To induce Buyer to enter into this Purchase
Contract and to purchase the offered Total Allocation, Seller hereby makes the representations,
warranties and covenants set forth in this paragraph, upon each of which Seller acknowledges and
agrees that Buyer is entitled to rely and has relied. Seller has corporate power and authority to
execute, deliver and perform its obligations under this Purchase Contract and this Purchase
Contract has been duly authorized, executed and delivered by Seller, constitutes the valid and
binding agreement of Seller and is enforceable in accordance with its terms. Seller is duly
organized and validly existing under the laws of North Carolina and in good standing. The
execution and delivery of and the performance by Seller of its obligations hereunder do not and
will not contravene, or constitute a default under, any provisions of applicable law or regulation,
or any agreement, judgment, injunction, order, decree or other instrument binding upon Seller or
result in the creation of any lien or other encumbrance on any asset of Seller. To Seller's
knowledge, there is no action, suit or proceeding pending or known to be threatened against or
affecting Seller in any court or before any arbitrator or before any governmental body which: (a)
in any manner raises any questions affecting the validity or enforceability of this Purchase Contract
or any other agreement or instrument to which Seller is a party or by which it is bound and that is
to be used in connection with, or is contemplated by, this Purchase Contract; (b) could adversely
affect the ability of Seller to perform its obligations hereunder, or under any document to be
delivered pursuant hereto; or (c) could adversely affect the offered Total Allocation or the use or
purposes thereof. Seller has not filed a petition or an answer seeking reorganization or an
arrangement with creditors or to take advantage of any insolvency or bankruptcy law.
(E) Representations and Warranties of Buyer. To induce Seller to enter into this Purchase
Contract and to sell the offered Total Allocation, Buyer hereby makes the representations and
warranties set forth in this paragraph, upon each of which Buyer acknowledges and agrees that
Seller is entitled to rely and has relied. This Purchase Contract has been duly executed and
delivered by Buyer, constitutes the valid and binding agreement of Buyer and is enforceable in
accordance with its terms. The execution and delivery of and the performance by Buyer of its
obligations hereunder do not and will not contravene, or constitute a default under, any provisions
of applicable law or regulation, or any agreement, judgment, injunction, order, decree or other
instrument binding upon Buyer or result in the creation of any lien or other encumbrance on any
asset of Buyer.
(F) Seller's Covenants. Seller shall cooperate with and assist, and shall take no action that might
impede, Buyer in obtaining the legal authorizations and regulatory approvals. Seller shall use
commercially reasonable efforts to maintain and avoid loss of any of Seller's offered Total
Allocation, and shall take no action that might reduce its value. In the event Seller becomes aware
of any action or event that potentially may cause loss, totally or partially, of the offered Total
Allocation, Seller shall promptly notify Buyer of such action or event.
Agree 1560

(G) Buyer's Covenants. Buyer shall submit its request for the transfer of the Total Allocation to
Buyer's NPDES permit immediately upon execution of this Purchase Contract; and Buyer shall
submit its request for the activation of the Total Allocation for Buyer's NPDES permit
immediately upon exercise of the Option and shall use its best efforts to obtain all legal and
regulatory authorizations as soon thereafter as practically possible. The failure of the proper
regulatory authority to issue the necessary approvals described herein shall not constitute an event
of default for either party, but shall afford either party the ability to elect to terminate this Purchase
Contract under sub -paragraph C hereof as an unsatisfied condition precedent.
(H) Remedies on Default. In the event of a default or other failure to perform hereunder by Buyer
of any of the terms, conditions and provisions of this Purchase Contract prior to closing, Seller,
upon written notice to Buyer, may terminate this Purchase Contract, retain the Option Money and
obtain from Buyer any reasonable costs incurred by Seller in connection with this transaction as
liquidated damages and in full and complete satisfaction of any and all claims of damages or causes
of action that Seller may have against Buyer. The parties hereby acknowledge that the actual
damages of Seller would be difficult to ascertain. In the event of a default or other failure to
perform hereunder by Seller of any of the terms, conditions and provisions of this Contract prior
to closing, Buyer, upon written notice to Seller, may terminate this Contract and receive from
Seller a refund of the Option Money plus any additional costs incurred by Buyer in connection
with this transaction as liquidated damages. The parties hereby acknowledge that the actual
damages of Buyer would be difficult to ascertain; except that, in the event Seller sells or otherwise
transfers to a person or entity other than Buyer all or any part of the offered Total Allocation during
the Option Period or after receiving from Buyer notice that Buyer is exercising the Option Seller
refuses to transfer the offered Total Allocation, Buyer may seek through a proceeding in equity
specific performance of Seller's obligations under this Contract.
6. Notice. For purposes of the Option and Contract, every notice or other communication required
herein shall not be effective unless the same shall be in writing and delivered personally to either
party or mailed by United States mail, Registered or Certified, postage prepaid, return receipt
requested, and if intended for Buyer, shall be addressed or personally delivered to:
City Manager
City of Gastonia
P.O. Box 1748
Gastonia, NC 28053-1748
and if intended by Seller, shall be addressed and personally delivered to:
5310 O\d 62v,\N4
C,,\Nom re, QC, 2.91.1-7
Notice to either Buyer or Seller shall be deemed effective from the time the same is deposited in
the United States Post Office, in an envelope, postage prepaid, addressed to either of the parties
herein.
Agree1560

7. Entire Agreement. The parties acknowledge this writing to constitute the entire agreement
between the parties and no amendment to the terms hereof shall be effective unless in writing and
signed by the parties.
8. Assignment. This Option and Contract may not be assigned by either party without the written
consent of the other party.
9. Severability. The invalidity or unenforceability of any terms or provisions hereto in any
jurisdiction shall in no way affect the validity or enforceability of any of the other terms or
provisions in that jurisdiction, or of the entire Agreement in any other jurisdiction.
10. Governing Law. This Agreement shall be deemed to have been made in the State of North
Carolina, and its validity, construction and effect shall be governed by the laws of the State of
North Carolina. The parties hereto agree that any action brought by either party to enforce the
terms of this Agreement shall be filed in the Superior Court of Gaston County, State of North
Carolina.
Agree1560

IN WITNESS WHEREOF, the parties hereto have, by authority duly given, caused the Option
and Contract to be executed as their official act the day and year first above written.
Cif Gastonia
By:
Attest:
By:Jit/ti A:Duivokoa,t6
(Deputy) C y Clerk
D. Bridgeman, Mayor
STATE OF NORTH CAROLINA
COUNTY OF GASTON
I, jti !IdliC Q Dw— / , a Notary Public of the aforesaid County and State, do
here y certify that 51.7ie yy' /.J- Dan a w personally appeared before me this day
and acknowledged that she is 'die (Deputy) City Clerk he City of Gastonia and that by authority
duly given and as the act of the municipal corporation, the foregoing instrument was signed in its
name by its Mayor, sealed with its corporate seal and attested by her as its (Deputy) City Clerk.
f�d�
WITNESS my hand and Notarial Seal, this the 2/ day of 201-7.
My Commission Expires:
Agree1560
o �p Oki/ �tary Pu • is
Gi jL1$
UNOTAp fr 2
commissi �YN
oEXPIRES —
'o2C� PUBLIC G,

STA 1 E OF NORTH CAROLINA
COUNTY OF GASTON
hne0t' 7"�` ,. a Notary Public of aforesaid County and State, do
hereby certify that 7 r J /.jc 4 r f Y'i personally appeared before me
this day and acknowledged that he is the /► of Lowell Investments I, LLC, a
North Carolina Limited Liability Company and b authority duly given and as the act of the
company, the foregoing instrument was signed in its name by him as its ei-
WITNESS my hand and Notarial Seal, this the 'day of Novell, bt,/ 20
My Commission Expires:
Agree1560
q /,Lii �-
tary Public
Notary Public
0 Mecklenburg
County —
MY Cornm. Exp. .77
/,,. 09-23-2622 T

ASTONIA
Contract Approvals/Certificates
CONTRACT: 20180061 -PURCHASE OF WASTEWATER NUTRIENT ALLOCATION
Approved as to form:
12/12/2017 3:41:43PM
This instrument has been preaudited in the manner required by the Local Government Budget and Fiscal
Control Act, Article 3, Chapter 159 of the General Statutes of North Carolina.
12/27/2017 2:59:33PM

.iliation Inquiry Summary
Il Number: 237025392812
Account Name: CITY OF GASTONIA GENERAL ACCOUNTS PAYABLE ACCOUNT
Bank ID: 053000196
GASTON
ACCOUNTING DMSION
PO BOX 1748
GASTONIA. NC 28063-1748
TN.how: n..Wan am.ma.a n.men., maima try Ito Lt. ow.m W.
Bu19Y.q F16.Caeol'cc
PAY
TO THE
ORDER
OF
Two Thousand Dollars and No Cents
LOWELL INVESTMENTS I, LLC
5320 OLD PINEVILLE ROAD
CHARLOTTE, NC 28217
..Na.
!AA NC
!ANIMA
111385 01/05/2018
132469
• pHECKANOUNT
82.000 00
c Ld
� , Services
Gry Maleger
Il 0 13 2469u' 1:053000196i: 23 70 2539 213 1 218
gl, <00001299, t Y. Cowan.). Bee
7
6028RT0 3800100
w -
Check Details
Check Number:
Account Number:
Account Name:
Bank ID:
132469
237025392812
CITY OF
GASTONIA
GENERAL
ACCOUNTS
PAYABLE
ACCOUNT
053000196
Amount: 2,000.00
Issue Date: 01/05/2018
Paid Date: 07/03/2018
Payee: LOWELL
INVESTMENTS I,
LLC
1
Bank ofAmeric:
Merrill Lynch

.filiation Inquiry Summary
Number: 237025392812
Account Name: CITY OF GASTONIA GENERAL ACCOUNTS PAYABLE ACCOUNT
Bank ID: 053000196
Bank of Americ-
Merrill Lynch
Electronic Endorsement Information
BOFD - Bank Of First Deposit
Bank Name: FIRST COMMUNITY BANK (BOFD)
Date: 07/03/2018
R/T:51501299
Sequence Number: 5015058460
Bank Name: BANK OF AMERICA, NA
Date: 07/03/2018
R/T: 111012822
Sequence Number: 004492627995
Bank Name: FEDERAL RES BANK OF
ATLANTA
Date: 07/05/2018
R/T: 61000146
Sequence Number: 3615260732
2

Water Resources
ENVIRONMENTAL QUALITY
November 14, 2017
Mr. David Shellenbarger
Assistant Division Manager, Compliance
Two Rivers Utilities
P.O. Box 1748
Gastonia, North Carolina 28053-1748
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Interim Director
Subject Proposed Transfer of Lowell
Investments' Nutrient Allocations
Long Creek WWTP
NPDFS Permit NC0020184
Gaston County
Dear Mr. Shellenbarger:
I have reviewed your September 12, 2017, outline of a potential agreement between Two Rivers
Utilities (TRU) and Lowell Investments for the transfer of nutrient allocations from the Lowell
Investments facility, NC0005274, to your Long Creek WWTP. In accordance with the 1995 Lake
Wylie Nutrient TMDL, Lowell Investments holds allocations of 1441b/day of total nitrogen
(TN) and 7.6 lb/day of total phosphorus ('1'P).
I believe that, in most respects, the outline provides a satisfactory framework for the transfer of -
these allocations. The Division of Water Resources could transfer the allocations to your Long
Creek facility in accordance with an acceptable sales agreement between the parties. The
transfer would be implemented by adding the allocations to the Nutrient Allocations special
condition of the Long Creek permit. The allocations would initially be designated as 'reserve'
but could be activated in the future to increase the facility's nutrient limits, consistent with the
Lake Wylie Nutrient TMDL.
Please note that the contract must transfer ownership of the allocations to TRU immediately
rather than merely provide an option for their future purchase. Each facility's nutrient
allocations are associated with its NPDES permit; thus, upon termination of Lowell
Investments' permit (expected in early 2018), any allocations it still holds will be eliminated and
no longer available to the company or to Two Rivers. As we discussed, the parties may be able
to craft a contract that executes the sale up front but defers payment until TRU needs to apply
the allocations.
In addition, the proposed 25-year duration of the agreement is excessive, given that significant
changes in the I .ake Wylie nutrient strategy could occur in that time. A 10- to 15-year term, with
the option to extend in 5-year increments, seems a more reasonable approach.
State of North Carolina Environmental Quality I Water Resources
1617 Mad Service Center ( Raleigh, North Carolina 27699-1617
919 807 6300

Proposed Transfer of Lowell
Investments' Nutrient Allocations
November 14, 2017
In response to your question, TRU does not in any way assume responsibility or liability for the
Lowell Investments site as the result of its purchase of the nutrient allocations.
Feel free to contact me at [phone] or [e-mail] if you have any
questions.
Sincerely,
Michael E. Templeton, P.E.
Water Quality Engineer
Enclosure: Proposed Option for Purchase Structure (TRU)
Copies: NPDES Files
Central Files
eCopies: Tom McKittrick, Lowell Investments I, LLC
Wes Bell, Mooresville Regional Office
2

Outline of possible Lowell InvesLinents-Two Rivers Utilities agreement (David Shellenbarger,
TRU, 9/12/2017 email to Templeton):
Proposed Option for Purchase Structure:
1. The City of Gastonia will agree to pay Lowell Investments $XXXXX for an option to
purchase the phosphorus and nitrogen Threshold Management Plan allocation from the
site at 1602 N Main Street, Lowell. At any time prior to the expiration of this agreement,
the City may purchase this allocation in its entirety for the sum of $XXXXX.
2. Lowell Investments and the City of Gastonia will request to modify their respective
NPDES Permits such that 100% of the phosphorus and nitrogen allocation currently in
the Lowell permit will be transferred to NPDES Permit NC0020184 for the City of
Gastonia's Long Creek WWTP.
3. Until this purchase is completed, Lowell Investments will retain ownership of the
nitrogen and phosphorus allocation, but it will be temporarily transferred to the City of
Gastonia with an option to purchase and will be listed as Reserved Allocation for the
Eagle Road and Long Creek Bubble Limit within NPDES Permit NC0020184.
4. The transaction shall be structured as a purchase option with a term of 25 years. If the
option has not been exercised the end of this term, the parties shall agree to negotiate
in good faith on a renewal. In the event no renewal agreement can be reached, the City
agrees to request removal of the subject reserve allocation from its NPDES permit(s).
5. If the 1995 Lake Wylie Threshold Management Plan is reopened in a manner that does
not preserve this reserve allocation, the City of Gastonia is not obligated for any further
compensation to Lowell Investments.
6. In the event the City of Gastonia does not utilize the Lowell Investments Allocation, no
cost shall be incurred by the City of Gastonia.
Obligations of Lowell Investments
• Submit to NCDEQ a permit rescission letter requesting the structure outlined above.
Obligations of the City of Gastonia
• Submit to NCDEQ a permit modification requesting the structure outlined above.
• Provide Lowell Investments notification and a report of any activation of the allocation
in the permit and any usage of the allocation in any monthly monitoring period
• Provide Lowell access to the City of Gastonia discharge data (DMRs) as needed.
NOTE: "Threshold Management Plan" refers to the Lake Wylie TMDL.

Annual Monitoring and Pollutant Scan
Permit No.: NC0006033
Outfall: 001
Month: June
Year: 2017
Facility Name : Eagle Road WWTP ORC : Cregg Beach (BORC)
Date of sampling : June 6, 2017 (total phenolics sampled 6-22-17) Phone : [phone]
Analytical Laboratory : City of Gastonia, Crowders Creek Lab (NC#210) and Shealy Environmental Services Inc. (NC#329)
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M
£ !�� ATF r �re 'D .'' y..
Sc:�S���i..-....+,..s ... .✓.7 aw.
Ammonia (as N)
C0610
Composite
SM4500 NH3 D
0.2
<0.2
mg/1
Chlorine (total residual, TRC)
50060
Grab
SM4500 CL G
20
23
ug/1
Dissolved Oxygen
00300
Grab
SM4500 0 G
0.1
8.7
mg/1
Nitrite plus Nitrate Total (as N)
00630
Composite
SM4500 NO3 F-NO2
0.5
28.4
mg/1
Total ICjeidahl Nitrogen
00625
Composite
SM4500 NORG C
1.0
<1.0
mg/1
Oil and Grease
00556
Grab
1664E
4.9
<4.9
mg/1
Total Phosphorus
C0665
Composite
SM4500 P E
0.05
0.8
mg/1
Total Dissolved Solids
70295
Composite
SM2540C-20
10
250
mg/1
Hardness
00900
Composite
SM2340C-20
10
44
mg/1
... ... i £ . F
111 a15%o.,, a(ile)aWek
'A
Jry ! .Syl
•� � .. a
rH .' S 9f 1
i'�, .i, 4'.ilk..,.._.
d Y�nJ iv A h. , . .
,..:.. i . _.. _..r,..
Antimony
01097
Composite
EPA 200.8
1.0
1.4
ug/1
Arsenic
01002
Composite
EPA 200.8
1.0
2.2
ug/1
Beryllium
01012
Composite
EPA 200.8
1.0
<1.0
ug/1
Cadmium
01027
Composite
EPA 200,8
1.0
<1.0
ug/1
Chromium
01034
Composite
EPA 200.8
1.0
2.2
ug/1
Copper
01042
Composite
EPA 200.8
1.0
4.9
ug/1
Lead
01051
Composite
EPA 200,8
1.0
<1.0
ug/1
Mercury (Method 1631E)****
COMER
Composite
EPA 1631E
1.0
<1.0
ng/I
Nickel
01067
Composite
EPA 200.8
1,0
2
ug/1
Selenium
01147 •
Composite
EPA 200.8
1,0
<1.0
ug/1
Silver
01077
Composite
EPA 200.8
1.0
<1.0
ug/1
Thallium
01059
Composite
EPA 200.8
1.0
<1.0
ug/1
Zinc
01092
Composite
EPA 200.8
10
42
ug/1
Cyanide
00720
Grab
SM 4500-CN
0.010
<0.010
mg/1
Total phenolic compounds ***
32730
Grab
EPA 420.4
0.005
0.0094
mg/1
Acrolein
34210
Grab
EPA 624
5.0
<5.0
ug/1
Acrylonitrile
34215
Grab
EPA 624
5,0
<5.0
ug/1
Benzene
34030
Grab
EPA 624
1.0
<1.0
ug/1
Bromoform
32104
Grab
EPA 624
1.0
<1.0
ug/1
Carbon Tetrachloride
32102
Grab
EPA 624
1.0
<1.0
ug/1
Chlorobenzene
34301
Grab
EPA 624
1.0
<1.0
ug/1
Chlorodibromomethane
34306
Grab
EPA 624
1.0
1.9
ug/1
Chloroethane
85811
Grab
EPA 624
2.0
<2.0
ug/1
2-chloroethyl vinyl ether
34576
Grab
EPA 624
5.0
<5.0
ug/1
Chloroform
32106
Grab
EPA 624
1.0
25
ug/1
Dichlorobromomethane
32101
Grab
EPA 624
1.0
7.0
ug/1
1,1-dichloroethane
34496
Grab
EPA 624
1.0
<1.0
ug/1
1,2-dichloroethane
32103
Grab
EPA 624
1.0
<1.0
ug/1
Trans-1,2-dichloroethylene
34546
Grab
EPA 624
1.0
<1.0
ug/1
1,1-dichlorocthylene
34501
Grab
EPA 624
1.0
<1.0
ug/1
1,2-dichloropropane
34541
Grab
EPA 624
1.0
<1.0
ug/l
1,3-dichloropropylene
77163
Grab
EPA 624
1.0
<1.0
ug/1
Ethylbenzene
34371
Grab
EPA 624
1.0
<1,0
ug/1
Methyl Bromide
. 34413
Grab
EPA 624
2,0
<2.0
ug/1
Form - DMR- PPA-1
Page 1

Annual Monitoring and Pollutant Scan
Permit No.: NC0006033
Outfall: 001
Month: June
Year: 2017
YA M
IJ
f
-iges
h
h �Smple,�
aIIIL
Methyl Chloride
34418
Grab
EPA 624
2.0
<2.0
ug/1
Methylene Chloride
34423
Grab
EPA 624
1.0
<1.0
ug/1
1,1,2,2-tetrachloroethane
81549
Grab
EPA 624
1.0
<1.0
ug/1
Tetrachloroethylene
34475
Grab
EPA 624
1.0
<1.0
ug/1
Toluene
34010
Grab
EPA 624
1.0
<1.0
ug/1
1,1,1-trichloroethane
34506
Grab
EPA 624
1.0
<1.0
ug/1
1,1,2-trlcbloroethane
34511
Grab
EPA 624
1.0
<1.0
ug/1
Trichloroethylene
39180
Grab
EPA 624
1.0
<1.0
ug/1
Vinyl Chloride
39175
Grab
EPA 624
1.0
<1.0
ug/1
trans-1,3-Dichloropropene '
34699 Grab
EPA 624
1.0
<1.0
ug/1
+ ci �vlAJf .m,' '::e :c.,om qYbju Rf df,f 1
;
' v
•ofx ..
.d �...v,:@.:..
.•.4...
trieLa3 _...,
a Kn.
.:. . . Pik r
P-chloro-m-creso
34452
Grab
EPA 625
1.6
<1.6
ug/1
2-chlorophenol
34586
Grab
EPA 625
1.6
<1.6
ug/1
2,4-dichlorophenol
34601
Grab
EPA 625
1.6
<1,6
ug/1
2,4-dimethylphenol
34606
Grab
EPA 625
1.6
<1.6
ug/1
4,6-dinitro-o-cresol
34657
Grab
EPA 625
8.0
<8.0
ug/1
2,4-dinitrophenol
34616
Grab
EPA 625
8.0
<8.0
ug/1
2-nitrophenol
34591
Grab
EPA 625
3.2
<3.2
ug/1
4-nitrophenol
34646
Grab
EPA 625
8.0
<8.0
ug/1
Pentachlorophenol
39032
Grab
EPA 625
8.0
<8.0
ug/1
Phenol
34694
Grab
EPA 625
1.6
<1.6
ug/1
2,4,6-tritc,hlorophe;}.n.ol
34621
Grab
EPA . 62.. 5
1.6
<1.6
TlsF ia1•ui
.
.n
... I ry,,s._.,..
.:,. ,....
ryug/1
.1:
Acenaphthene
34205
Grab
EPA 625
1.6
<1.6
ug/1
Acenaphthylene
34200
Grab
EPA 625
1.6
<1.6
ug/1-
Anthracene
CO220
Grab
EPA 625
1.6
<1,6
ug/1
Benzidine
39120
Grab
EPA 625
8.0
<8.0
ug/1
Benzo(a)anthracene
34526
Grab
EPA 625
1.6
<1.6
ug01. -
Benzo(a)pyrene
34247
Grab
EPA 625
1.6
<1.6
• ug/1
3,4 benzoiluoranthene
34230
Grab
EPA 625
1.6
<1.6
ug/1
Benzo(ghi)perylene
34521
Grab
EPA 625
1,6
<1.6
ug/1
Benzo(k)fluoranthene
34242
Grab
EPA 625
1.6
<1.6
ug/1
Bis (2-cbloroethoxy) methane
34278
Grab
EPA 625
1.6
<1.6
ug/1
Bis (2-chloroethyl) ether
34273
Grab
EPA 625
1.6
<1,6
ug/1
Bis (2-chloroisopropyl) ether
34283
Grab
EPA 625
1.6
<1.6
ug/1
Bis (2-ethylhexyl) phthalate
39100
Grab
EPA 625
1.6
<1.6
ug/1
4-bromophenyl phenyl ether
34636
Grab
EPA 625
1.6
<1.6
ug/1
Butyl benzyl phthalate
.34292
Grab
EPA 625
1.6
<1.6
ug/1
2-chloronaphthalene
34581
Grab
EPA 625
1.6
<1.6
ug/1
4-chlorophenyl phenyl ether
34641
Grab
EPA 625
1.6
<1.6
ug/1
Chrysene
34320
Grab
EPA 625
1.6
<1.6
ug/1
Di-n-butyl phthalate
39110
Grab
EPA 625
1.6
<1.6
ug/1
Di-n-•octylphthalate
34596
Grab
EPA 625
1.6
<1.6
ug/1
Dibenzo(a,h}anthracene
34556
Grab
EPA 625
1.6
<1,6
ug/1
1,2-dichiorobenzene •
34536
Grab
EPA 625
1.6
<1,6
ug/1
1,3-dichlorobenzene
34566
Grab
EPA 625
1,6
<1.6
ug/1
1,4-dichlorobenzene
34571
Grab
EPA 625
1.6
<1.6
ug/1
3,3-d1chlorobenzidine
34631
Grab
EPA 625
8.0
<8.0
ug/1
Diethyl phthalate
34336
Grab
EPA 625
1.6
<1.6
ug/1
Dimethyl phthalate
34341
Grab
EPA 625
1.6
<1.6
ug/1
Form - DMR- PPA-1
Page 2

Annual Monitoring and Pollutant Scan
Permit No.: NC0006033
Outfall: 001
Month: June
Year: 2017
PMOM ter
Pairametel
Code:
Sample
a
Anal tic ' Method
Quaitl:ltatibit
level
Sample
Ro 4t r
iT xts of
Measurement
2,4-dinitrotoluene
34611
Grab
EPA 625
3.2
<3.2
ug/1
2,6-dinitrotoluene
CO626
Grab
EPA 625
3.2
<3.2
ug/1
1,2-diphenylhydrazine
34346
Grab
EPA 625
1,6
<1.6
ug/1
Fluoranthene
CO376
Grab
EPA 625
1.6
<1,6
ug/1
Fluorene
34381
Grab
EPA 625
1.6
<1.6
ug/1
Hexachlorobenzene
C0700
Grab
EPA 625
1.6
<1.6
ug/1
Hexachlorobutadiene
39702
Grab
EPA 625
1.6
<1.6
ug/1
Hexachlorocyclo-pentadiene
34386
Grab
EPA 625
8.0
<8.0
ug/1
Hexachloroethane
34396
Grab
EPA 625
1.6
<1,6
ug/1
Indeno(1,2,3-cd)pyrene
34403
Grab
EPA 625
1,6
<1.6
ug/1
Isophorone
34408
Grab
EPA 625
1.6
<1.6
ug/1
Naphthalene
34696
Grab
EPA 625
1.6
<1.6
ug/1
Nitrobenzene
34447
Grab
EPA 625
1.6
<1.6
ug/1
N-nitrosodi-n-propylar ine
34428
Grab
EPA 625
1.6
<1.6
ug/1
N-nitrosod methylamine
34438
Grab
EPA 625
1.6
<1,6
ug/1
N-nitrosodiphenylamine
34433
Grab
EPA 625
1,6
<1.6
ug/1
Phenanthrene
34461
Grab
EPA 625
1.6
<1.6
ug/1
Pyrene
34469
Grab
EPA 625
1.6
<1.6
ug/1
1,2,4,-trichlorobenzene
34551
Grab
EPA 625
1.6
<1.6
ug/1
** Additional parameter run per method 624.
*** Total phenolic compounds sampled 6-22-17.
**** The EPA 1631E, FRB, exceeded acceptable limits, but data is considered valid.
"I certify, under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance with a
system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person
or persons who managed the system, or those persons directly responsible for gathering the information, the information submitted is, to the best
of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information,
including the possibility of fines and imprisonment for knowing violations."
Authorized Representative name
Date
Form - DMR- PPA-1 Page 3

Annual Monitoring and Pollutant Scan
Permit No. NC006033
Outfall 001
Month - September
Year - 2018
Facility Name : Eagle Road C✓WTP ORC : Hugh Hampton
Date of sampling : September 14, 2018 Phone : [phone]
Analytical Laboratory : City of Gastonia, Crowders Creek Lab (NC#210) and Shealy Environmental Services Inc. (NC#329)
+'0 cr ;�',-
1 a �
°�
��nPLe
`'+'
'A 1--.
SM4500 NH3 D
-.
�Q.iusntita
<0.2
mg/1
rs
0.2
Ammonia (as Nj
C0610
Composite
50060
Grab
SM4500 CL G
20
<20
ug/1
Chlorine (total residual, TRC)
Dissolved Oxygen
00300
Grab
SM4500 0 G
0.1
7.0
mg/1
Nitrite plus Nitrate Total (as N)
00630
Composite
SM4500 NO3 F-NO2
0.5
21.2
mg/1
Total Kjeldahl Nitrogen
00625
Composite
SM4500 NORG C
1.0
<1.0
mg/1
Oil and Grease
00556
Grab
1664B
5.3
<5.3
mg/1
Total Phosphorus
C0665
Composite
SM4500 P E
0.05
0.8
mg/1
Total Dissolved Solids
70295
Composite
SM2540C-20
25
290
mg/1
Hardness
00900
Composite
SM2340C-20
10
35
mg/1
1xe„ ,o 0 Ya,d$n'"i`lg
,.
Antimony
01097
Composite
EPA 200.8
1.0
1.4
ug/1
Arsenic
01002
Composite
EPA 200.8
1.0
<1.0
ug/1
Beryllium
01012
Composite
EPA 200.8
1.0
<1.0
ug/1
Cadmium
01027
Composite
EPA 200.8
0.5
<0.5
ug/1
Chromium
01034
Composite
EPA 200.8
1.0
<1.0
ug/1
Copper
01042
Composite
EPA 200.8
1.0
5.2
ug/1
Lead
01051
Composite
EPA 200.8
1.0
<1.0
ug/1
Mercury (Method 1631E)
COMER
Composite
EPA 1631E
1.0
1.62
ng/1
Nickel
01067
Composite
EPA 200.8
1.0
2.4
ug/1
Selenium
01147
Composite
EPA 200.8
1.0
<1.0
ug/1
Silver
01077
Composite
EPA 200.8
1.0
<1.0
ug/1
Thallium
01059
Composite
EPA 200.8
1.0
<1.0
ug/1
01062
Composite
EPA 200.8
1.0
<1.0
ug/1
Molybdenum***
Zinc
01092
Composite
EPA 200.8
10
26.8
ug/1
Cyanide
00720
Grab
SM 4500-CN
0.010
<0.010
mg/1
Total phenolic compounds
32730
Grab
EPA 420.4
0.005
<0.005
mg/1
atAttAcrolein
_
34210^
Grab
EPA 624
5.0
<5.0
ug/1
Acrylonitrile
34215
Grab
EPA 624
5.0
<5.0
ug/1
Benzene
34030
Grab
EPA 624
1.0
<1.0
ug/1
Bromoform
32104
Grab
EPA 624
1.0
<1.0
ug/1
Carbon Tetrachloride
32102
Grab
EPA 624
1.0
<1.0
ug/1
Chlorobenzene
34301
Grab
EPA 624
1.0
<1.0
ug/1
Chlorodibromomethane
34306
Grab
EPA 624
1.0
2.2
ug/I
Chloroethane
85811
Grab
EPA 624
2.0
<2.0
ug/1
2-chloroethyl vinyl ether
34576
Grab
EPA 624
5.0
<5.0
ug/1
Chloroform
32106
Grab
EPA 624
1.0
16
ug/1
Dichlorobromomethane
32101
Grab
EPA 624
1.0
6.1
ug/1
1,1-dichloroethane
34496
Grab
EPA 624
1.0
<1.0
ug/1
1,2-dichloroethane
32103
Grab
EPA 624
1.0
<1.0
ug/1
Trans-1 2-dichloroethylene
34546
Grab
EPA 624
1.0
<1.0
ug/1
1,1-dichloroethylene
34501
Grab
EPA 624
1.0
<1.0
ug/1
1,2-dichloropropane
34541
Grab
EPA 624
1.0
<1.0
ug/1
1,3-dichloropropylene
77163
Grab
EPA 624
1.0
<1.0
ug/1
Ethylbenzene
34371
Grab
EPA 624
1.0
<1.0
ug/1
Form - DMR- PPA-1
Page 1

Permit No. NC006033
Annual Monitoring and Pollutant Scan
Month - September
Year - 2018
0
a- anie
P ii r
C-,u_e:
am. *
s -.,e
., "?
Hain aa„1 .td
..
4.u_nlfita ip'�0
eve
a lei
.u1
e= 0-
eas n.uM,ea.
Methyl Bromide
34413
Grab
EPA 624
2.0
<2.0
ug/1
Methyl Chloride
34418
Grab
EPA 624
2.0
<2.0
ug/1
Methylene Chloride
34423
Grab
EPA 624
1.0
<1.0
ug/1
1,1,2,2-tetrachloroethane
81549
Grab
EPA 624
1.0
<1.0
ug/1
Tetrachloroethylene
34475
Grab
EPA 624
1.0
<1.0
ug/1
Toluene
34010
Grab
EPA 624
1.0
<1.0
ug/1
1,1,1-trichloroethane
34506
Grab
EPA 624
1.0
<1.0
ug/I
1, 1,2-trichloroethane
34511
Grab
EPA 624
1.0
<1.0
ug/1
Trichloroethylene
39180
Grab
EPA 624
1.0
<1.0
ug/1
Vinyl Chloride
39175
Grab
EPA 624
1.0
<1.0
ug/1
1,2-Dichlorobenzene**
34356
Grab
EPA 624
1.0
<1.0
ug/1
1,3-Dichlorobenzene**
34566
Grab
EPA 624
1.0
<1.0
ug/1
1,4-Dichlorobenzene**
34571
Grab
EPA 624
1.0
<1.0
ug/1
Dichlorodifluoromethane**
34668
Grab
EPA 624
2.0
<2.0
ug/1
cis-1,2-Dichloroethene**
77093
Grab
EPA 624
1.0
<1.0
ug/1
1,2,4-Tiichlorobenzene**
34551
Grab
EPA 624
1.0
<1.0
ug/1
Trichlorofluormethane**
34488
Grab
EPA 624
1.0
<1.0
ug/1
e i ao
,(ouns
P chloro m-creso
34452
Grab
EPA 625
1.6
<1.6
ug/1
2-chlorophenol
34586
Grab
EPA 625
1.6
<1.6
ug/1 ,
2,4 dichlorophenol
34601
Grab
EPA 625
1.6
<1.6
ug/1
2,4 dimethylphenol
34606
Grab
EPA 625
1.6
<1.6
ug/1
4,6-dinitro-o-cresol
34657
Grab
EPA 625
8.0
<8.0
ug/1
2,4-dinitrophenol
34616
Grab
EPA 625
8.0
<8.0
ug/1
2-nitrophenol
34591
Grab
EPA 625
3.2
<3.2
ug/1
4-nitrophenol
34646
Grab
EPA 625
8.0
<8.0
ug/1
Pentachiorophenol
39032
Grab
EPA 625
8.0
<8.0
ug/1
Phenol
34694
Grab
EPA 625
1.6
<1.6
ug/1
2 4 6-trichlorophenol
34621
Grab
EPA 625
1.6
<1.6
ug/1
Bes ' aC<e''`-:" Iu A
k°
-'�
,,�..
r'-'s..
Acenaphthene
34205
Grab
EPA 625
1.6
<1.6
ug/1
Acenaphthylene
34200
Grab
EPA 625
1.6
<1.6
ug/1
Anthracene
CO220
Grab
EPA 625
1.6
<1.6
ug/1
Benzidine
39120
Grab
EPA 625
8.0
<8.0
ug/1
Benzo(a)anthracene
34526
Grab
EPA 625
1.6
<1.6
ug/1
Benzo(a)pyrene
34247
Grab
EPA 625
1.6
<1.6
ug/1
3,4 benzofluoranthene
34230
Grab
EPA 625
1.6
<1.6
ug/1
Benzo(ghi)perylene
34521
Grab
EPA 625
1.6
<1.6
ug/1
Benzo(k)fluoranthene
34242
Grab
EPA 625
1.6
<1.6
ug/1
Bis (2-chloroethoxy) methane
34278
Grab
EPA 625
1.6
<1.6
ug/I
Bis (2-chloroethyl) ether
34273
Grab
EPA 625
1.6
<1.6
ug/1
Bis (2-chloroisopropyl) ether
34283
Grab
EPA 625
1.6
<1.6
ug/1
Bis (2-ethythexyl) phthalate
39100
Grab
EPA 625
1.6
<1.6
ug/1
4-bromophenyl phenyl ether
34636
Grab
EPA 625
1.6
<1.6
ug/1
Butyl benzyl phthalate
34292
Grab
EPA 625
1.6
<1.6
ug/I
2-chloronaphthalene
34581
Grab
EPA 625
1.6
<1.6
ug/1
4-chlorophenyl phenyl ether
34641
Grab
EPA 625
1.6
<1.6
ug/1
Chrysene
34320
Grab
EPA 625
1.6
<1.6
ug/1
Di-n-butyl phthalate
39110
Grab
EPA 625
1.6
<1.6
ug/1
Di-n-octyl phthalate
34596
Grab
EPA 625
1.6
<1.6
ug/I
Form - DMR- PPA-1
Page 2

Annual Monitoring and Pollutant Scan
Permit No. NC006033
Outfall 001
Month - September
Year -2018
" =
•
Paraii- erg.
'Goat
ae
�'AtYPe
uaatd:ib ':-.
^'' xft
a Tinlfs''o
.., 8 :
uC�„e
al alMes °rd.�.�.
Dibenzo(a,h)anthracene
34556
Grab
EPA 625
1.6
<1.6
ug/1
1,2-dichlorobenzene
34536
Grab
EPA 625
1.6
<1.6
ug/1
1,3-dichlorobenzene
34566
Grab
EPA 625
1.6
<1.6
ug/1
34571
Grab
EPA 625
1.6
<1.6
ug/1
1,4 dichlorobenzene
3,3-dichlorobenzidine
34631
Grab
EPA 625
8.0
<8.0
ug/1
Diethyl phthalate
34336
Grab
EPA 625
1.6
<1.6
ug/I
Dimethyl phthalate
34341
Grab
EPA 625
1.6
<1.6
ug/1
2,4 dinitrotoluene
34611
Grab
EPA 625
3.2
<3.2
ug/1
2,6-dinitrotoluene
CO626
Grab
EPA 625
3.2
<3.2
ug/l
1,2-diphenylhydrazine
34346
Grab
EPA 625
1.6
<1.6
ug/1
Fluoranthene
C0376
Grab
EPA 625
1.6
<1.6
ug/1
Fluorene
34381
Grab
EPA 625
1.6
<1.6
ug/1
Hexachlorobenzene
CO700
Grab
EPA 625
1.6
<1.6
ug/1
Hexachlorobutadiene
39702
Grab
EPA 625
1.6
<1.6
ug/1
Hexachlorocyclo-pentadiene
34386
Grab
EPA 625
8.0
<8.0
ug/1
Hexachloroethane
34396
Grab .
EPA 625
1.6
<1.6
ug/1
Indeno(1,2,3-cd)pyrene
34403
Grab
EPA 625
1.6
<1.6
ug/1
Isophorone
34408
Grab
EPA 625
1.6
<1.6
ug/1
Naphthalene
34696
Grab
EPA 625
1.6
<1.6
ug/1
Nitrobenzene
34447
Grab
EPA 625
1.6
<1.6
ug/1
N-nitrosodi-n-propylamine
34428
Grab
EPA 625
1.6
<1.6
ug/1
N-nitrosodimethylamine
34438
Grab
EPA 625
1.6
<1.6
ug/1
N-nitrosodiphenylamine
34433
Grab
EPA 625
1.6
<1.6
ug/I
Phenanthrene
34461
Grab
EPA 625
1.6
<1.6
ug/1
Pyrene
34469
Grab
EPA 625
1.6
<1.6
ug/1
1,2,4,-trichlorobenzene
34551
Grab
EPA 625
1.6
<1.6
ug/I
** Additional parameters run per method 624.
*** Additional Parameter run per method EPA 200.8
"I certify, under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance with a
system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person
or persons who managed the system, or those persons directly responsible for gathering the information, the information submitted is, to the best
of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information,
including the possibility of fines and imprisonment for knowing violations."
Authorized Representative name
Signature
It- 5-18
Date
Form - DMR- PPA-1 Page 3

Annual Monitoring and Pollutant Scan
Permit No. NC006033
Outfall 001
Facility Name : Eagle Road WWTP
Date of sampling : March 7, 2019
Month - March
Year - 2019
ORC : Hugh Hampton
Phone : [phone]
Analytical Laboratory : City of Gastonia, Crowders Creek Lab (NC#210) and Shealy Environmental Services Inc. (NC#329)
p eter
oc e
Sam le
Anal. cal cfhod
Qu nt�fat�on
e ei
.....
�F-
sul
fs of
i easJiremex►t
arameter
mow.. �.,..,
�.
��w.
,_.�
R
NH3 D
0.1
<0.10
mg/1
Ammonia
(as N)
C0610
Composite
SM4500
Chlorine
(total residual,
TRC)
50060
Grab
SM4500 CL G
20
20
ug/1
Dissolved
Oxygen
00300
Grab
SM4500 0 G
0.1
11.9
mg/1
0.5
19.4
Nitnte
Nitrate Total
(as N)
00630
Composite
SM4500 NO3 F-NO2
mg/1
plus
Total
Kjeldahl
Nitrogen
00625
Composite
SM4500 NORG C
1.0
<1.0
mg/1
Grab
1664B
5.1
<5.1
mg/1
Oil
and Grease
00556
0.05
1.2
Total
Phosphorus
C0665
Composite
SM4500 P E
mg/1
Total
Dissolved
Solids
70295
Composite
SM2540C-20
25
260
mg/1
50
Hardness
00900
Composite
SM2340C-20
10
mg/1
Metal
(iifn ecove�rablej, cyaxud
aut otat
pfieno sr
1.0
<1.0
Antimony
01097
Composite
EPA
200.8
ug/1
1.0
<1.0
Arsenic
01002
Composite
EPA
200.8
ug/1
EPA
200.8
1.0
<1.0
ug/1
Beryllium
01012
Composite
Cadmium
01027
Composite
EPA
200.8
0.5
<0.5
ug/1
EPA
200.8
1.0
<1.0
ug/1
Chromium
01034
Composite
1.0
3.2
Copper
01042
Composite
EPA
200.8
ug/1
Lead
01051
Composite
EPA
200.8
1.0
<1.0
ug/1
1.16
Mercury
(Method
1631E)
COMER
Composite
EPA
1631E
1.0
ng/1
Nickel
01067
Composite
EPA
200 8
1.0
1
ug/1
1.0
Selenium
01147
Composite
EPA
200.8
<1.0
ug/1
Silver
01077
Composite
EPA
200.8
1.0
<1.0
ug/1
Thallium
01059
Composite
EPA
200.8
1.0
<1.0
ug/1
EPA
200.8
1.0
<1.0
ug/1
Molybdenum***
01062
Composite
10
26
Zinc
01092
Composite
EPA
200.8
ug/1
Cyanide
00720
Grab
SM
4500-CN
0.010
<0.10
mg/1
EPA 420.4
0.005
<0.005
mg/1
Total
phenolic
compounds
32730
Grab
:ram-,;.'.,
':.'r/`.,'
"r,: -m- ,..ter.,n=
.,,r'
-'_;,...�....,-=r.�R✓
�oI#31e
�organu
a
ic�copa
Acrolein
34210
Grab
EPA 624
5.0
<5.0
ug/1
Acrylonitnle
34215
Grab
EPA
624
5.0
<5.0
ug/1
Benzene
34030
Grab
EPA
624
1.0
<1.0
ug/1
EPA
624
1.0
<1.0
ug/1
Bromofoinn
32104
Grab
Carbon
Tetrachloride
32102
Grab
EPA
624
1.0
<1.0
ug/1
34301
Grab
EPA
624
1.0
<1.0
ug/1
Chlorobenzene
EPA
624
1.0
<1.0
ug/1
Chlorodibromomethane
34306
Grab
Chloroethane
85811
Grab
EPA
624
2.0
<2.0
ug/1
34576
Grab
EPA
624
5.0
<5.0
ug/1
2-chloroethyl
vinyl ether
EPA
624
1.0
23
ug/1
Chloroform
32106
Grab
EPA
624
1.0
3.7
ug/1
Dichlorobromomethane
32101
Grab
1,1-dichloroethane
34496
Grab
EPA
624
1.0
<1.0
ug/1
1,2-dichloroethane
32103
Grab
EPA
624
1.0
<1.0
ug/1
Trans-1,2-dichloroethylene
34546
Grab
EPA
624
1.0
<1.0
ug/1
1,1-dichloroethylene
34501
Grab
EPA
624
1.0
<1.0
ug/1
34541
Grab
EPA
624
1.0
<1.0
ug/1
1,2-dichloropropane
1,3-dichloropropylene
77163
Grab
EPA
624
1.0
<1.0
ug/1
EPA
624
1.0
<1.0
ug/1
Ethylbenzene
34371
Grab
Form - DMR- PPA-1
Page 1

Annual Monitoring and Pollutant Scan
Permit No. NC006033
Outfall 001
Month - March
Year - 2019
Parameter
parameteramrle
Codeppe
Fnalyt
calethodepe
Qatatto
Samttle
ResultX2easure
Qs
of
erifi
Grab
EPA
624
2.0
<2.0
ug/1
Methyl Bromide
34413
Methyl Chloride
34418
Grab
EPA
624
2.0
<2.0
ug/1
Methylene
Chloride
34423
Grab
EPA
624
1.0
<1.0
ug/1
81549
Grab
EPA
624
1.0
<1.0
ug/1
1,1,2,2-tetrachloroethane
34475
Grab
EPA
624
1.0
<1.0
ug/1
Tetrachloroethylene
34010
Grab
EPA
624
1.0
<1.0
ug/1
Toluene
34506
Grab
EPA
624
1.0
<1.0
ug/1
1, 1, l-tnchloroethane
Grab
EPA
624
1.0
<1.0
ug/1
1,1,2-tnchloroethane
34511
Trichloroethylene
39180
Grab
EPA
624
1.0
<1.0
ug/1
Vinyl
Chloride
39175
Grab
EPA
624
1.0
<1.0
ug/1
1.0
<1.0
34356
Grab
EPA
624
ug/1
1,2-Dichlorobenzene**
1.0
<1.0
34566
Grab
EPA
624
ug/1
1,3-Dichlorobenzene**
34571
Grab
EPA
624
1.0
<1.0
ug/1
1,4-Dichlorobenzene**
2.0
<2.0
Grab
EPA
624
ug/1
Dichlorodifluoromethane**
34668
cis-1
2-Dichloroethene**
77093
Grab
EPA
624
1.0
<1.0
ug/1
1.0
<1.0
34551
Grab
EPA
624
ug/1
1
2,4-Tnchlorobenzene**
EPA
624
1.0
<1.0
ug/1
Tnchlorofluoiu
ethane**
34488
Grab
a
ACid
eRftaCtalile
Compounds
'
err
z-
,,.�.�_,--,,
;. �.�.,-�'"''.."
. ,...,..'."`�, r
t.
.. -':,-
.-,-,�.
..rw...,�-.
Grab
EPA
625
1.6
<1.6
ug/1
P-chloro-m-creso
34452
2-chlorophenol
34586
Grab
EPA
625
1.6
<1.6
ug/1
2,4-dichlorophenol
34601
Grab
EPA
625
1.6
<1.6
ug/1
34606
Grab
EPA
625
1.6
<1.6
ug/1
2,4-dimethylphenol
Grab
EPA
625
8.0
<8.0
ug/1
4,6-dinitro-o-cresol
34657
2,4-dmitrophenol
34616
Grab
EPA
625
8.0
<8.0
ug/1
34591
Grab
EPA
625
3.2
<3.2
ug/1
2-nitrophenol
34646
Grab
EPA
625
8.0
<8.0
ug/1
4-nitrophenol
Pentachlorophenol
39032
Grab
EPA
625
8.0
<8.0
ug/1
Phenol
34694
Grab
EPA
625
1.6
<1.6
ug/1
2
4,6-trichlorophenol
34621
Grab
EPA
625
1.6
<1.6
ug/1
$ase
Ico
nnds
�
�
�
",r
neutr
a`
� �~
�
"-ram_
�_ u✓
��
v,, <_ r ,
.�
X .� �� .
_
34205
Grab
EPA
625
1.6
<1.6
ug/1
Acenaphthene
Acenaphthylene
34200
Grab
EPA
625
1.6
<1.6
ug/1
Anthracene
CO220
Grab
EPA
625
1.6
<1.6
ug/1
Benzidine
39120
Grab
EPA
625
8.0
<8.0
ug/1
Benzo(a)anthracene
34526
Grab
EPA
625
1.6
<1.6
ug/1
Benzo(a)pyrene
34247
Grab
EPA
625
1.6
<1.6
ug/1
3,4
benzofluoranthene
34230
Grab
EPA
625
1.6
<1.6
ug/1
Grab
EPA
625
1.6
<1.6
ug/1
Benzo(ghi)perylene
34521
Benzo(k)fluoranthene
34242
Grab
EPA
625
1.6
<1.6
ug/1
EPA
625
1.6
<1.6
ug/1
Bis
(2-chloroethoxy)
methane
34278
Grab
Bis
(2-chloroethyl)
ether
34273
Grab
EPA
625
1.6
<1.6
ug/1
Bis
(2-chloroisopropyl)
ether
34283
Grab
EPA
625
1.6
<1.6
ug/1
EPA
625
8.0
<8.0
ug/1
Bis
(2-ethylhexyl)
phthalate
39100
Grab
Grab
EPA
625
1.6
<1.6
ug/1
4-bromophenyl
phenyl
ether
34636
Butyl
benzyl
phthalate
34292
Grab
EPA
625
1.6
<1.6
ug/1
34581
Grab
EPA
625
1.6
<1.6
ug/1
2-chloronaphthalene
4-chlorophenyl
phenyl
ether
34641
Grab
EPA
625
1.6
<1.6
ug/1
Chrysene
34320
Grab
EPA
625
1.6
<1.6
ug/1
Di-n-butyl
phthalate
39110
Grab
EPA
625
1.6
<1.6
ug/1
EPA 625
1.6
<1.6
ug/1
Di-n-octyl
phthalate
34596
Grab
Form - DMR- PPA-1
Page 2

Annual Monitoring and Pollutant Scan
Permit No. NC006033
Outfall 001
Month - March
Year - 2019
Paretexode
.
�.��. ., �,,,,...
parameter
., , ._.. �,..,
ame
hype
�... ,. ,
E>tnaLyiieal tviethod
...._.�._ v,.d, r,...,,....
Quantztatiampie
.� level
,.
,.,�
Rsult ��
..�-
iTn
Nieasueme%
u.,.s _r...
.�r,,..
_,,U
34556
Grab
EPA
625
1.6
<1.6
ug/1
Dibenzo(a,h)anthracene
34536
Grab
EPA
625
1.6
<1.6
ug/1
1,2-dichlorobenzene
1,3-dichlorobenzene
34566
Grab
EPA
625
1.6
<1.6
ug/1
1,4-dichlorobenzene
34571
Grab
EPA
625
1.6
<1.6
ug/1
34631
Grab
EPA
625
8.0
<8.0
ug/1
3,3-dichlorobenzidine
34336
Grab
EPA
625
1.6
<1.6
ug/1
Diethyl
phthalate
34341
Grab
EPA
625
1.6
<1.6
ug/1
Dimethyl
phthalate
2,4-dmitrotoluene
34611
Grab
EPA
625
3.2
<3.2
ug/1
2,6-dmitrotoluene
C0626
Grab
EPA
625
3.2
<3.2
ug/1
1 2-diphenylhydrazine
34346
Grab
EPA
625
1.6
<1.6
ug/1
Fluoranthene
C0376
Grab
EPA
625
1.6
<1.6
ug/1
34381
Grab
EPA
625
1.6
<1.6
ug/1
Fluorene
Hexachlorobenzene
C0700
Grab
EPA
625
1.6
<1.6
ug/1
Hexachlorobutadiene
39702
Grab
EPA
625
1.6
<1.6
ug/1
Hexachlorocyclo-pentadiene
34386
Grab
EPA
625
8.0
<8.0
ug/1
34396
Grab
EPA
625
1.6
<1.6
ug/1
Hexachloroethane
Indeno(1,2,3-cd)pyrene
34403
Grab
EPA
625
1.6
<1.6
ug/1
Isophorone
34408
Grab
EPA
625
1.6
<1.6
ug/1
34696
Grab
EPA
625
1.6
<1.6
ug/1
Naphthalene
Nitrobenzene
34447
Grab
EPA
625
1.6
<1.6
ug/1
EPA
625
1.6
<1.6
ug/1
N-mtrosodi-n-propylamine
34428
Grab
EPA
625
1.6
<1.6
ug/1
N-mtrosodunethylamine
34438
Grab
EPA
625
1.6
<1.6
ug/1
N-mtrosodiphenylamine
34433
Grab
Phenanthrene
34461
Grab
EPA
625
1.6
<1.6
ug/1
Pyrene
34469
Grab
EPA
625
1.6
<1.6
ug/1
Grab
EPA
625
1.6
<1.6
ug/1
1,2,4-trichlorobenzene
34551
** Additional parameters run per method 624.
*** Additional Parameter run per method EPA 200.8
"I certify, under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance with a
system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person
or persons who managed the system or those persons directly responsible for gathering the information, the information submitted is, to the best
of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information,
including the possibility of fines and imprisonment for knowing violations."
Authorized Representative name
(Lk.,"
Signature
4-27-491
Date
Form - DMR- PPA-1 Page 3

CITY OF GASTONIA, NORTH CAROLINA
TWO RIVERS UTILITIES
PHARR YARNS, LLC
SANITARY SEWER SERVICE
UTILITY AGREEMENT
THIS SANLTARY SEWER SERVICE UTILITY AGREEMENT (this "Agreement"), made and entered
into the 4hlay of 2013 (the "Effective Date"), by and between the City of Gastonia, a North Carolina
municipal corporation, h einafter referred to as "City" or "TRU", and Pharr Yarns, LLC, a North Carolina limited
liability company, hereinafter referred to as "Customer" ("City", "TRU" and "Customer" are sometimes hereinafter
referred to as "Party" or the "Parties" collectively);
WITNESSETH:
That in consideration of, and subject to, the terms and conditions hereinafter set forth, the parties covenant and agree
as follows:
1. Purchase and Sale. Customer agrees to buy wastewater treatment services from TRU, and TRU agrees to
sell wastewater treatment services to Customer on the terms and conditions set forth in this Agreement. The
wastewater treatment services being sold by TRU shall at all times meet the standards for treatment of wastewater as
promulgated pursuant to the terms of the Clean Water Act at 33 USCA Sections 1251 through 1387, all as amended
from time to time, which standards have been adopted by the State of North Carolina Department of Health,
Environment, and Natural Resources, Division of Water Quality, under which standards TRU treats wastewater at its
wastewater treatment plants. TRU shall be the sole provider of wastewater treatment services to Customer; provided,
however, if TRU fails to provide the Maximum Capacity or Maximum Flow Rate (defined in Section 8 herein), in
addition to its other remedies, Customer may contract with another provider or construct its own facilities or
otherwise provide cover to address the excess; provided further, if Customer's wastewater'treatment needs exceed
the Maximum Capacity or Maximum Flow Rate, Customer may contract with another provider or construct its own
facilities or otherwise provide cover to address the excess.
2. Term. (a) This Agreement shall be effective from and after the Effective Date and shall continue and
remain in full force and effect for a period of twenty-five (25) years from and after the date upon which wastewater is
first treated for Customer pursuant to the terms of this Agreement (the "Commencement Date"). During the ninety
(90)-day period beginning on the date twenty-two (22) years from and after the Commencement Date, TRU may give
notice to the Customer of its desire to renew this Agreement for another twenty-five (25) year term, and upon the
giving of such notice, the Parties hereto shall negotiate in good faith with reference to a renewal of this Agreement
based upon the same terms and conditions contained in this Agreement, including the Applicable Rate (defined
herein).
(b) If for any reason; (i) the infrastructure described in Paragraph 4 is not constructed, (ii) City fails to receive grant
funds from the North Carolina Clean Water Management Trust Fund, or (iii) the City fails to receive a loan from the
State Revolving Loan fund bearing an interest rate of zero percent (0%), this agreement shall terminate.
3. Contribution by Customer. Within sixty (60) days after the completion and approval of surveys as set forth
in subsection 3(e), Customer or one or more of its affiliates shall:
(a) Convey to TRU marketable fee simple title to such real property as necessary for the construction
of a wastewater treatment pump station to TRU. The real property conveyed shall be of the size
and location substantially as shown in Exhibit A which is attached hereto and incorporated by
reference. The real property to be conveyed shall not exceed one (1) acre and will be located
surrounding the existing wastewater treatment plant operated by the Town of McAdenville.
(b) Convey to TRU easements for gravity and force sewer mains, lines and appurtenances over and
across the real property shown on Exhibit B which is attached hereto and incorporated herein by
reference. The easements to be conveyed shall be substantially in the locations shown on Exhibit
B provided however, that should topographical or engineering constraints require the realignment

of such easements, the City shall submit a map showing the requested realignment to Customer for
its approval, which approval shall not be unreasonably withheld. If Customer does not respond to
such submittal within 15 days, the proposed alignment shall be deemed to be approved.
(c) Convey to TRU such temporary slope and construction easements for and during the period of
construction as shall be reasonably requested by TRU for the construction of the Project as
described in Section 4. Such easements shall expire no later than the date that is (6) months after
the Project Completion Date.
(d) All permanent easements conveyed pursuant to this paragraph shall be at least thirty (30) feet in
width unless TRU determines that some lesser width is appropriate. If two sewer lines must be
located within the easement or if the sewer line is installed at a depth of more that twelve (12) feet,
Customer shall convey an easement at least forty (40) feet in width.
(e) Within six (6) months after the Effective Date, TRU shall have completed surveys of all of the
areas described in subsections (a), (b) and (c) above and submitted same to Customer for its
approval, which approval shall not be unreasonably withheld. If Customer does not respond to
such submittal within fifteen (15) days, the proposed surveyed locations shall be deemed to be
approved.
4. Construction of Additional Facilities.
(a) TRU shall design and construct or contract for the design and construction of such sanitary sewer
infrastructure as is necessary to convey wastewater from the existing Customer wastewater
treatment plant to the existing TRU collection system ("Infrastructure") as shown on the map
attached hereto as Exhibit C and incorporated herein by reference, pursuant to this Agreement.
Prior to commencing any work on property owned by Customer, TRU shall notify Customer of the
identity of all contractors with whom TRU has entered into contracts for completion of the
Infrastructure, who will be entering Customer's property and the scope of work to be completed by
such contractors. All construction shall be in compliance with applicable federal, state and local
statutes, rules, regulations and ordinances. All construction of Infrastructure shall be completed in
a good and workmanlike manner consistent with standards for similarly -situated facilities in North
Carolina within thirty (30) months of the Effective Date ("Project Completion Date").
(b) Costs associated with the design and initial construction of the Infrastructure shall be the
responsibility of TRU; provided, however, that TRU may enter into agreements with third parties
concerning the funding of such costs. All contractors hired by TRU to perform work on property
owned by Customer shall carry insurance as provided in Section 14 with respect to such
construction activities and TRU shall provide certificates of such insurance to Customer.
(c) Upon completion, the Infrastructure located from the connection point with TRU's existing
collection system up to and including the manifold point, as shown on Exhibit C, shall belong to
TRU and become a part of its wastewater collection and treatment system. Upon completion, TRU
shall have completed as -built plans showing the actual location of all portions of the Infrastructure,
and TRU will provide a copy of such as -built plans to Customer. The remainder of the
Infrastructure shall belong to Customer and shall be maintained and operated by Customer.
(d) As soon as possible after the Commencement Date but in no event more than three months after
the Commencement Date, TRU shall commence repair of any damages and restore Customer's
property in a good and workmanlike manner so that the disturbed areas are substantially in the
same condition existing prior to commencement of work. Such repair and restoration work shall
be completed by the earlier of 6 months after the Commencement Date or the Project Completion
Date.
(e) Prior to construction of the metering point, TRU shall submit a representation of the proposed
exterior appearance of said metering point to Customer for Customer's approval. If Customer does
not respond to such submittal within fifteen (15) days, the proposed exterior appearance shall be
deemed to be approved.

5. Decommissioning of Existing Plant.
(a) TRU shall contract for the decommissioning and demolition of Customer's existing wastewater
treatment plant, consisting of basins, buildings and associated equipment ("Plant") as shown on
Exhibit D which is attached hereto and incorporated herein by reference, and pay any costs
associated therewith except as hereinafter provided. TRU shall be responsible for all costs related
to the disposal of materials resulting from the decommissioning and demolition provided that such
materials can be disposed of by land application or in a lined landfill. To the extent that any
materials require disposal in any other manner, including without limitation, a hazardous waste
landfill, Customer shall reimburse TRU for all costs related to such disposal in excess of the costs
TRU would have incurred had the materials been disposed of by land application or in a lined
landfill.
(b)
Any contract entered into by TRU for the demolition of the basins shall provide that basin concrete
shall be demolished and removed to a point three feet below pre -demolition grade and openings
shall be placed at the bottom of each basin to provide for groundwater control. Remaining concrete
shall be allowed to remain place. TRU shall provide and place sufficient clean fill on the Plant site
to bring the property up to proper grade as set forth in subsection 5(c) but shall not be responsible
for the compaction of such fill. Customer shall contract for the placement and compaction of the
fill to the level that Customer deems appropriate. Customer hereby releases and holds TRU, its
officers, employees, and agents harmless from against any and all liability, actions, debts, claims,
and demands of every kind whatsoever, specifically including any claim for negligence or
negligent acts or omissions, arising from or related to the portions of the concrete basins allowed to
remain in place and the manner and level of compaction of fill as described herein.
(c) All decommissioning and demolition work shall be performed in a good and workmanlike manner
by licensed and qualified contractors in compliance with applicable federal, state and local
statutes, rules, regulations and ordinances. All decommissioning and demolition work shall be
commenced not later than three (3) months after the Commencement Date and be completed by the
Project Completion Date. Upon completion of the decommissioning and demolition, the grade
level of the property shall reflect the most efficient grading necessary to drain the site.
(d) Any equipment located in the Plant shall be disposed of by TRU or TRU's contractor as part of the
demolition and decommissioning. Customer shall be responsible for removing all other equipment
located outside of the Plant.
(e) TRU shall submit an invoice, including supporting documentation, to Customer for any costs for
which Customer is responsible, which shall be due and payable within 30 days after submission.
6. Operation of System. TRU shall operate and maintain its wastewater collection and treatment system
consistent with all state and federal laws and in as efficient a manner as possible consistent with standards generally
observed in North Carolina by operators of similarly -situated facilities. TRU shall remedy any failures in said
system with all possible dispatch. In the event of an extended inability to furnish sewage treatment services at the
volumes set out herein, the services to Customer shall be maintained in the same proportion of the total services
remaining after the reduction that it was entitled to before such reduction.
7 Price of Wastewater Treatment. TRU will bill and Customer will pay to TRU, on a monthly basis for all
metered wastewater discharged to TRU's wastewater system from Customer, an amount equal to the prevailing rate
for nonresidential customers inside the City as set forth on the then -current published Water and Sewer Rate
Schedule, and such schedule is revised and published from time to time by TRU (hereinafter, the "Applicable Rate").
Monthly billing shall be defined as TRU's ongoing billing cycle for the area in which the meter involved is located.
8. Maximum Capacity and Maximum Flow Rate. TRU shall provide capacity for Customer to have a
maximum monthly wastewater flow of 15,000,000 gallons per month (the "Maximum Capacity"). Wastewater flows
shall not exceed a maximum instantaneous flow of 1,215 gallons per minute (the "Maximum Flow Rate"). The
Maximum Capacity may be reviewed from time to time during the term of this Agreement and may be revised

through written amendment to the Agreement. In the event Customer exceeds the Maximum Capacity, TRU shall
have the right to increase the rate charged to Customer for the amount of wastewater treated which exceeds the
Maximum Capacity, said charge not to exceed 1.9 times the then -current Applicable Rate.
9. Minimum Wastewater Flow Limit.
(a) Except as provided in subsections (b) and (c) of this Section, TRU shall bill Customer for
treatment of a minimum amount of wastewater flow of 2,500,000 gallons per month ("Minimum
Gal/Month") whether or not such wastewater flow amount is delivered by Customer each month
during the term of this Agreement. The Minimum Gal/Month may be reviewed from time to time
during the term of this Agreement and may be revised through written amendment to the
Agreement as provided for hereinafter.
On or before January 30 of each year of the term of this Agreement, TRU shall determine the total
amount of wastewater measured by the metering point or points serving both Customer and the
Town of McAdenville for each month of the previous calendar year or portion thereof ("Total
Cumulative Monthly Flow"). TRU shall provide Customer with an annual report showing the
total amount by which the Cumulative Monthly Flow exceeds 3,400,000 gallons ("Excess Monthly
Flow"), plus any Excess Monthly Flow remaining from prior years. So long as there is a balance
of Excess Monthly Flow, Customer shall only be required to pay for the actual metered wastewater
flow rather than the Minimum Gal/Month, provided however, that the balance of Excess Monthly
Flow shall be reduced by difference between the actual metered flow and the Minimum Gal/Month
for any month that the actual metered flow is less than the Minimum Gal/Month. Nothing in this
paragraph shall be construed to allow the Customer to pay for less than the actual metered flow.
Attached hereto as Exhibit E is an illustration of how the Parties intend the credits to work in
practice.
(c) If at any time during the term of the Agreement, the Customer and the Town of McAdenville have
been billed and paid for wastewater treatment services for a cumulative total of 742,000,000
gallons, Customer shall for the remainder of the term of this Agreement be billed only for the
actual amount discharged into TRU's system and shall no longer be subject to the Minimum
Gal/Month as set forth in subsection (a) above.
(b)
10. Equalization of Wastewater Flow. Customer shall be required to equalize wastewater flows delivered to the
TRU's system at a flow rate based upon the wastewater flow limits established in its Significant Industrial User
Permit from time to time.
11. Invoicing. Bills for wastewater treatment supplied hereunder shall be rendered and paid monthly. A
"month" shall mean the period between any two regular consecutive billing period readings of the meter measuring
the quantity of wastewater flow in the TRU's system.
12. Significant Industrial User. Customer shall be, in the same manner as all other significant industrial users of
the sanitary sewer system of TRU, subject to all provisions of City's Sewer Use and Industrial Pretreatment
Ordinance ("Ordinance") in effect at the time of execution of this Agreement and as they may be amended from time
to time. Customer shall administer its own industrial pretreatment program. Notwithstanding its status as a
significant industrial user, Customer shall be subject to the Applicable Rate as set forth in Section 7, provided,
however, that Customer shall be subject to any surcharges, fees or penalties assessed for violations of or
noncompliance with the Ordinance or Customer's significant industrial user permit.
13. Use of Wastewater Treatment Plant Capacity. During the term of this Agreement, TRU will provide to
Customer wastewater treatment up to the Maximum Capacity. At such time, however, that Customer utilizes
12,000,000 gallons per month (80% of 15,000,000) of such Maximum Capacity for six consecutive billing periods,
TRU and Customer agree to negotiate in good faith a higher Maximum Capacity. In the event TRU must expand its
wastewater facilities in order to provide such higher flow limit to Customer, Customer agrees to pay for its
proportionate share of the costs of the expansion at the time TRU incurs those costs associated with the expansion
necessary to provide such higher flow to Customer.

14. Insurance. During the period beginning on the Effective Date and ending on the Project Completion Date,
TRU shall maintain commercial general liability insurance which shall provide coverage for bodily injury and
property damage (except automotive equipment) in the following limits of liability: For bodily injury and property
damage; $1,000,000.00 each occurrence with an aggregate limit of not less than $3,000,000.00.A11 contractors hired
by TRU to perform work on property owned by Customer shall maintain insurance policies, including without
limitation, a commercial general liability policy, in such amounts as are generally required by the City of Gastonia
for construction projects of a similar size and complexity. TRU shall require any contractor hired to perform work
on property owned by Customer to name Customer as an additional insured on the contractor's commercial general
liability policy.
15. Force Majeure. In the event either TRU or Customer is unable, in whole or in part, by reason of force
majeure to carry out its obligations, other than to make payments for wastewater treatment services received, it is
agreed that on giving notice of such force majeure as soon as possible after the occurrence of the cause relied upon,
then the obligation of TRU or Customer, so far as each may be affected by such force majeure, shall be suspended
from performance hereunder during the continuance of any inability so caused, but for no longer period, and such
cause shall as far as possible, be remedied with all due speed. The term "force majeure" shall mean acts of God,
strikes, lockouts or other industrial disturbances, acts of public enemy, war blockades, riots, landslides, droughts,
storms, floods washouts, arrests and restraints of governments and people, civil disturbances, explosions, inability to
obtain rights -of -way or permits or materials and equipment and supplies, and any other cause not within control of
TRU or Customer, which by the exercise of reasonable diligence by TRU or Customer, is not preventable.
16. Waivers. Neither the failure nor delay on the part of either Party hereto to exercise any right, power or
privilege hereunder shall operate as a waiver thereof, nor shall any single or partial exercise of any other right, power
or privilege, and no custom or practice at variance with the terms of the Agreement shall constitute a waiver of the
right of either Party to demand exact compliance with such terms.
17. Invalid Terms. Should any one or more of the provisions contained in this Agreement be held invalid,
illegal, or unenforceable in any respect, the validity, legality and enforceability of the remaining provisions contained
in this Agreement shall not in any way be affected or impaired thereby, and this Agreement shall otherwise remain in
full force and effect.
18. Assignment. Neither party may assign this Agreement without the prior written consent of the other party
which consent shall not be unreasonably withheld except that Customer will have the right without the consent of
TRU to transfer or assign this Agreement to any affiliate of Customer or any other person or entity which controls, is
controlled by or is under common control with Customer, or to any entity which succeeds Customer by merger or
consolidation, or to any entity which Customer is converted into, or to any entity which acquires the goodwill and
substantially all of the other assets of Customer.
19. Controlling Law/Successors Bound. This Agreement and the rights and obligations of the parties hereunder
shall be construed and interpreted in accordance with the laws of the State of North Carolina and shall be binding
upon and inure to the benefit of the successors and, with consent of the other party, the assigns of either party hereto.
20. Counterparts. This Agreement may be executed in any number of counterparts, each of which when so
executed and delivered shall be deemed an original.
21. Notices. Any notices required or permitted in this Agreement, including address changes, shall be made in
writing and shall be made either by mailing registered or certified mail, return receipt requested, and postage
prepaid, to the other party at the address shown herein for that party or at such different address for that party, notice
of which has been properly given hereunder, or by personally delivering such a notice to an officer or other party.
The notice, if mailed as provided for herein, shall be deemed given on the day of receipt or refusal to accept receipt,
and if personally delivered, on the date of delivery. The addresses are as follows:

TO TRU:
Director of Two Rivers Utilities
City of Gastonia
P.O. Box 1748
Gastonia, NC 28053
TO CUSTOMER:
Pharr Yarns, LLC
100 Main Street
McAdenville, NC 28101
Attn: President
22. Entire Agreement. This Agreement reflects and contains the entire and only agreement between the parties
relating to the subject matter herein, and as such supersedes all negotiations, commitments, undertakings and
agreements, whether oral or otherwise.
23. Amendments. This Agreement may be amended only by an instrument in writing executed by both parties
hereto.
24. Dispute Resolution. In addition to and prior to litigation, the parties shall endeavor to settle disputes first
by negotiation between the parties, and, if negotiation is unsuccessful, then by non -binding mediation. Demand
for mediation shall be filed in writing with the other party to this Agreement. A demand for mediation shall be
made within a reasonable time after the claim, dispute or other matter in question has arisen. In no event shall the
demand for mediation be made after the date when institution of legal or equitable proceedings based on such
claim, dispute or other matter in question would be barred by the applicable statute of repose or limitations. Each
party hereto submits to the exclusive jurisdiction in the state and federal courts having jurisdiction in Gaston County,
North Carolina and irrevocably waives any defenses to such venue including any defense based upon the principles
of forum non conveniens.
List of Exhibits Attached to This Agreement:
Exhibit A — Property to be Conveyed in Fee
Exhibit B — Location of Easements to be Conveyed
Exhibit C — Location of Infrastructure
Exhibit D — Pharr Yarns' Existing Wastewater Treatment Plant
Exhibit E — Calculation of Credits
[Signature(s) appear on the following page(s)]

IN WITNESS WHEREOF, the undersigned have caused the Agreement to be executed in their behalf by individuals
duly authorized, all as of the day and year first above written.
GA
.•` 0,......••... •,. CITY' GASTONIA, NORTH CAROLINA
DVS s9�
;SEAL; By: �...-
O pork. John-
- I Brid;lman, Mayor
APPROVED AS TO FORM:
(SEAL)
PHARR YARNS, LLC
By: W G'WcGN P cQaw+-.
William P. Carstarphen, Preside t
(Remainder of page intentionally ;eft blank)

STATE OF NORTH CAROLINA
COUNTY OF GASTON
1, Retina Lv.1sn,,,hIllips , a Notary Public of the aforesaid County and State, do hereby certify that
\.% i r9 n • a. L. Creip} h+vr` personally appeared before me this day and acknowledged that she is the
City Clerk of the City ofastonia and that by authority duly given and as the act of the municipal corporation, the
foregoing instrument was signed in its name by its Mayor, sealed with its corporate seal and attested by her as its
City Clerk.
WITNESS my hand and Notarial Seal, this the 9 day of 440- , 2013. \�\\011111110 ///
•�., w)P..L A i
� tip%
NotaPv Public
My Commission Expires: 3.11. d01$
STATE OF NORTH CAROLINA
COUNTY OF ,�ra.s f pn
NOTARY N=
PUBLIC —
llllllll
I, fi n n C � j er k I ins , a Notary Public of the County and State aforesaid, certify that
wi Il 1 ek rn P. Cars farp/,ew_ , personally appeared before me this day and acknowledged that s/he is
n (`F_ c/ �g t of PhaYarns, LLC., a limited liability company, and that by authority duly given and as the
i act of the company, the foregoing instrument was signed in its name by him/her.
WITNESS my hand and Notarial Seal, this 3D day of -u. 1 1 , 2013.
My Commission Expires: j'Y\a r _k JI, �Q /?
Agree1308
\\\\ \c IJ E N �
NOTAR
PURL►C
ts'% y ��
. C.i.
otary Public

EXHIBIT A
Real Property Description
[see attached map — legal description to be drafted from survey]

BELMONT LAND & INVESTMENT CO
3585056470
ELMONT LAN
3
BELMONT LA
•
& INV .TMENT CO
85057 .5
CATA
NVES ENT CO
5 41910
Legend
Proposed Pump Station Parcel
Proposed Easement Parcels
Owner
PHARR YARNS LLC
BELMONT LAND & INVESTMENT CO
STOWE MILLS INC
WESLEYAN DEVELOPMENT LLC
MCADENVILLE TOWN OF
Q LOWELL TOWN OF
Parcels
BELMONT LAND & INVESTMENT CO
3585141910
NVILLE TOWN 0
3585140559
WESLEYAN DEVELOPMENT LLC
3585133992
BELMONT LAND & INVESTMEN CO
3585049359
1 inch = 80 feet
A LANDS CONSERVANCY
3585136474
Exhibit A

EXHIBIT B
Easements
[see attached map — legal description to be drafted from survey]

Legend
///
Proposed Phase 2 Easements
Proposed Easement Parcels
Owner
PHARR YARNS LLC
BELMONT LAND & INVESTMENT CO
STOWE MILLS INC
WESLEYAN DEVELOPMENT LLC
MCADENVILLE TOWN OF
LOWELL TOWN OF
Add_Pharr_prcl
Parcels
1-
0
}
BELMONT LAND & INVESTMENT CO g
3575858226
ww**
•
1�
WESLEYA
NO NAME
riordramrwarAniravAr
575944976
\
400 Feet
1 inch = 400 feet
STOE1
W�Ia S INC
3585050,4
•
PHA - '
5
PHARR YARNS LLC
3585056470
PHARR YARNS LLC
3585141910
Exhibit B
RR YAR
8505773
HARR YARNS
3585141910
MCADE
3
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p
S

EXHIBIT C
Location of Infrastructure
[See attached Map]

Legend
Proposed Sewer Mains
Phase, Gravity, Force Main
— Phase 2, Force Main
—0-- Phase 2, Gravity
Proposed Pump Station Parcel
Proposed Easement Parcels
Owner
PHARR YARNS LLC
BELMONT LAND & INVESTMENT CO
STOWE MILLS INC
WESLEYAN DEVELOPMENT LLC
MCADENVILLE TOWN OF
LOWELL TOWN OF
ST
o F
CC co F
wEr-1 c
2 >-ry j h 0
CC co
co'c' o u
w
co
Proposed Forcemain
Proposed
Manifold Point
QP
Pharr
Space Dye
Facility
ELM S
MAIN S
0
a Q-
HIGHLAND ST a Z0
co v
{v�
NEE eYl
G,1
S�S��
,SO
_ 59
'O
o
4� ��1'
Existing Duhart O� i„F
Pump Station w4`-
G
IS H1N331N3A3S
cy44RcN sT
LEATHCO ST
SMITH RD
w"otisON BCVD
Y'
oGI
� s,G y PC0
FeP 0 OA
tA N
A
KEVIEW DR
Proposed
Pumpstation
Exhibit C

EXHIBIT D
Pharr Yarns' Existing Wastewater Treatment Plant

Upper Aerated Storage Basin
(to be demolished in place)
Proposed location of connection
of existing forcemains
(will require shutdown of
roadway for a limited time)
Lower Aerated Storage Basin
(to be demolished in place)
STOWE MILLS INC
3585050986
Storage Building
(to be demolished in place)
Solids Handling Building
(to be demolished in place)
Circular Clarifiers
(to be demolished in place)
Storage Buildings (2)
(to be demolished in place)
Water Filtration Plant Inlet
(to remain in service)
Water Filtration Plant
(to remain in service)
Equipment Storage Area
(Slab and any equipment
not included decommissioning)
1 inch = 60 feet
Legend
• — Carolina Thread Trail
=Proposed Easement Parcels
RailRoads
100 Year Flood
Pharr WWTP
Chlorine Contact Chamber
r4 (to be demolished in place)
Exhibit D

EXHIBIT E
Calculation of Credits
[see attached Excel spreadsheet]

CALCULATION OF CREDITS
EXHIBIT E
ILLUSTRATION - ASSUMES A JULY COMMENCEMENT DATE
Month
(a) (b) (a)+(b)=(c) (d) (c)-(d)=(e) (c)-(d)=(f)
Pharr Town of if positive if negative
Yarns McAdenville Total
Monthly Monthly Cumulative Minimum
Wastewater Wastewater Monthly Gallons / Earned Applied Available
Flow Flow Flow Month Credit Credit Credit
July Year 1 2,902,000 900,000 3,802,000 3,400,000 402,000 -
August Year 1 3,675,000 932,000 4,607,000 3,400,000 1,207,000 -
September Year 1 3,212,000 928,000 4,140,000 3,400,000 740,000 -
October Year 1 3,860,000 931,000 4,791,000 3,400,000 1,391,000
November Year 1 4,263,000 887,000 5,150,000 3,400,000 1,750,000 -
December Year 1 3,381,000 855,000 4,236,000 3,400,000 836,000 -
6,326,000 6,326,000
Credit carried forward to Year 2: 6,326,000
January Year 2 3,470,000 926,000 4,396,000 3,400,000 996,000 -
February Year2 3,558,000 929,000 4,487,000 3,400,000 1,087,000 -
March Year2 3,841,000 833,000 4,674,000 3,400,000 1,274,000
April Year 2 3,550,000 935,000 4,485,000 3,400,000 1,085,000 May Year 2 3,758,000 887,000 4,645,000 3,400,000 1,245,000
June Year2 3,822,000 902,000 4,724,000 3,400,000 1,324,000 -
July Year2 2,902,000 1,265,000 4,167,000 3,400,000 767,000 -
August Year2 3,675,000 1,286,000 4,961,000 3,400,000 1,561,000
September Year2 3,212,000 1,292,000 4,504,000 3,400,000 1,104,000
October Year 2 3,860,000 1,288,000 5,148,000 3,400,000 1,748,000 -
November Year2 4,263,000 1,292,000 5,555,000 3,400,000 2,155,000
December Year2 3,381,000 1,321,000 4,702,000 3,400,000 1,302,000
15,648,000 15,648,000
Credit carried forward to Year 3: 21,974,000
January Year 3 3,470,000 1,265,000 4,735,000 3,400,000 1,335,000
February Year 3 3,558,000 1,286,000 4,844,000 3,400,000 1,444,000 -
March Year3 3,841,000 1,292,000 5,133,000 3,400,000 1,733,000 - -
April Year 3 3,550,000 1,288,000 4,838,000 3,400,000 1,438,000
May Year 3 2,758,000 1,292,000 4,050,000 3,400,000 650,000
June Year3 2,322,000 1,321,000 3,643,000 3,400,000 243,000 -
July Year3 1,902,000 1,265,000 3,167,000 3,400,000 (233,000) (233,000)
August Year 3 1,675,000 1,286,000 2,961,000 3,400,000 (439,000) (439,000)
September Year 3 2,475,000 1,292,000 3,767,000 3,400,000 367,000
October Year 3 2,235,000 1,288,000 3,523,000 3,400,000 123,000 -
November Year 3 2,450,000 1,292,000 3,742,000 3,400,000 342,000 -
December Year 3 1,381,000 1,321,000 2,702,000 3,400,000 - (698,000) (698,000)
Total Cumulative Gallons 130,279,000
7,675,000 7,675,000
Credit carried forward to Year 4: 28,279,000

2,0 ll-PDOl3,- g-8
NORTH CAROLINA
GASTON COUNTY
AMENDMENT TO SANITARY SEWER
SERVICE UTILITY AGREEMENT
THIS AMENDMENT TO SANITARY SEWER SERVICE UTILITY AGRREMENT (this
"Amendment") is made and entered into the t ( day of 4tJ4cL� t , 2017, by
and between the City of Gastonia, a North Carolina municipal core tion, hereinafter referred to
as "City" or "TRU" and Pharr Yarns, LLC, a North Carolina limited liability company, hereinafter
referred to as "Customer" ("City, "TRU" and "Customer" are sometimes hereinafter referred to as
"Party" or "Parties" collectively).
WITNESSETH:
Whereas, City and Customer previously entered into that certain Sanitary Sewer Service Utility
Agreement dated August 9, 2013 (the "Agreement"); and,
Whereas, the Agreement provided, among other things, that the City would construct certain
infrastructure within thirty months of the Effective Date of the Agreement; and,
Whereas, due to changed circumstances, including, but not limited to, the failure to receive the
funding specified in the Agreement, it became impossible for the infrastructure to be completed
within the time stated in the Agreement and for the Parties to perform their respective obligations
to each other as provided in the Agreement; and,
Whereas, funding in reduced amounts have now been received; and,
Whereas, the Parties wish to re -affirm the Agreement and proceed with the mutual covenants and
obligations contained in the Agreement, except as amended herein;
Now, Therefore, in consideration of the mutual covenants contained in this Amendment; and, in
consideration of the terms and conditions set forth in the Agreement, as amended herein, the Parties
covenant and agree as follows:
A. Paragraph 3(c) of the Agreement is hereby amended by deleting the last sentence of said
paragraph and replacing it with the following sentence:
"Such easements shall expire no later than the date that is six (6) months after the infrastructure to
be constructed by City has been completed."
Agree1308a

B. Paragraph 3(e) of the Agreement is hereby amended by deleting the first sentence of said
paragraph and replacing it with the following sentence:
"Within six (6) months after the date of this Amendment TRU shall have completed surveys of all
of the areas described in subsections (a), (b) and (c) above and submitted same to Customer for its
approval, which approval shall not be unreasonably withheld".
C. Paragraph 4(a) of the Agreement is hereby amended by deleting the last sentence of said
paragraph and replacing it with the following sentence:
"All construction of Infrastructure shall be completed in a good and workmanlike manner
consistent with standards for similarly -situated facilities in North Carolina within thirty (30)
months of the date of this Amendment ("Project Completion Date")."
D. Paragraph 5 of the Agreement is hereby amended by being deleted in its entirety and replacing
it with the following paragraph:
5. Decommissioning of Existing Plant.
"Customer shall contract for the decommissioning and demolition of Customer's existing
wastewater treatment plant at Customer's cost All decommissioning and demolition work shall
be performed in a good and workmanlike manner by licensed and qualified contractors in
compliance with all applicable federal, state and local statutes, rules, regulations and ordinances.
All decommissioning and demolition work on the Customer's wastewater treatment plant shall be
completed no later than (6) months after City has completed construction of the infrastructure
referenced in this Agreement. Customer agrees to submit a written request to NCDEQ to rescind
its NPDES permit as soon as City sewer is available and to provide a copy of same to the City. "
E All other terms and conditions of the Agreement are hereby ratified and confirmed by the
Parties and the Parties agree to proceed with the fulfillment of their respective obligations under
the Agreement, as amended, immediately upon the execution of this Amendment.
IN WITNESS WHEREOF, the undersigned have caused this Amendment to be executed in their
behalf by individuals duly autjjprimdr.11 as of the day and year first above written.
• .. �s 0 1st
O ,
Sig,L
:y0�'7.. `•�P`r`c' By: '
Att• t: '%9Ty p„?�c` /�o. D. Brig •e ,Mayor
City of Gastonia, North Carolina
Agree1308a

Attorney/�L44/
(Ai
Pharr Yarns, LLC
B
William P. Carstarphen, P /. sident
STATE OF NORTH CAROLINA
COUNTY OF GASTON
I, 6L421h/je "C%j835 , a Notary Public of the aforesaid County and State, do
hereby certify that C'a,,f )ce Cr. Z)itend y , personally appeared before me this day and
acknowledged that she is Clerk of the City of Gastonia and that by authority duly given
and as the act of the muri l aTotporation, the foregoing instrument was signed in its name by
its Mayor, sealed with its corporate seal and attested by her as its City Clerk.
it
Witness my hand and Notarial Seal, this the //day of St , 2017.
My Commission Expires: fi /11-fP
No at blic
STATE OF NORTH CAROLINA
COUNTY OF GASTON
I, ad -her i r\2 j . Pp n ✓l I n Notary Public of the County and State aforesaid, certify
that William P Carstarphen, pers ally appeared before me this day and acknowledged that s/he
is President of Pharr Yarns, LLC., a limited liability company, and that by authority duly given
and as the act of the company, the foregoing instrument was signed in its name by him/her
Witness my hand and Notarial Seal, this f alAliayofA-Lil 'fir- , 2017. My Commission Expires: A-usys.si' 13t a0aa CJ,9-. to `
Notary ��1?;yyrr
oe
Agree1308a 4 :Bt.%O :�

1 °NIA;
Cr atflac i C tni Peppier. r , ,.r Pro -Anise.
Supplemental Contract Approvals/Certificates
CONTRACT: 20140012 - UTILITY AGREEMENT- W WT FOR PHARR YARNS
Approved as to form:
8/11/2017 3:05:45PM
This instrument has been preaudited in the manner required by the Local Government Budget and Fiscal
Control Act, Article 3, Chapter 159 of the General Statutes of North Carolina.

Scheringer, Stephanie
From: Graham, Charles (Legal)
Sent: Friday, December 18, 2020 1:46 PM
To: Scheringer, Stephanie
Subject: FW: Pharr Yarns
Stephanie,
See the email chain below. Pharr has the right to assign the SSSUA to an entity under the same control/ownership as
Pharr Yarns so we can't object to the transfer. You will need to let me know what needs to happen to transfer the SIU as
requested and I suppose billing should now be made to Selkirk. As soon as I Amy gives me an answer on who they deem
to be the owner of the private collection system we will need to verify the state agrees and finish working toward that
takeover.
Charles L. Graham, Jr.
Assistant City Attorney
The City of Gastonia
P.O. Box 1748
Gastonia, NC 28053-1748
Phone: [phone]
Fax: [phone]
Email: [e-mail]
From: Graham, Charles (Legal)
Sent: Friday, December 18, 2020 1:42 PM
To: 'Rickers, Amy' <[e-mail]>
Cc: Kendall, Nick <[e-mail]>
Subject: RE: Pharr Yarns
Thank you for providing clarification on the assignment of the agreement. We will let you know what will be required in
order to issue the SIU to Selkirk Realty, LLC.
With regard to the private collection system, is Pharr or Selkirk now the owner? It also appears that with the property
transfers that line now crosses properties owned by both Selkirk and Belmont Land and Investment. Is that correct? As
we work through the transfer of that system we will need to accurately reflect the correct owner and secure the
necessary easements from the correct property owners.
Charles L. Graham, Jr.
Assistant City Attorney
The City of Gastonia
P.O. Box 1748
Gastonia, NC 28053-1748
Phone: [phone]
Fax: [phone]
Email: [e-mail]
From: Rickers, Amy [mailto:[e-mail]]
Sent: Friday, December 18, 2020 12:53 PM
To: Graham, Charles (Legal) <[e-mail]>
1

Cc: Kendall, Nick <[e-mail]>
Subject: RE: Pharr Yarns
CAUTION: This email originated from outside of the organization. Do not click links or open attachments
unless you recognize the sender and know the content is safe.
Charles -
If I understand your concern, you want to better understand who the customer is for the SSSUA. Pharr Yarns, LLC has
assigned the rights and responsibilities under the SSSUA to Selkirk Realty LLC, an affiliated entity under common control
with Pharr Yarns, LLC. IT seems that Selkirk Realty LLC would be the proper entity for billing and permitting. Please let
me know if you need further information or wish to discuss further.
Regards,
Amy
From: Graham, Charles (Legal) <[e-mail]>
Sent: Monday, December 7, 2020 12:51 PM
To: Rickers, Amy <[e-mail]>
Cc: Scheringer, Stephanie<[e-mail]>; Albright, Joe <[e-mail]>
Subject: Pharr Yarns
Amy,
Our wastewater staff has received a request from representatives at Pharr to change the name on Pharr's SIU permit to
Selkirk Properties, LLC. If a company simply changes its name then we would simply change the name on the
permit. Since Selkirk is technically a separate legal entity it may be more involved than a simple name change. Based on
your recent question regarding application of the flow from the private collection system and this name change request
I would like to have some clarification.
As you and I have discussed, we know the SSSUA between Pharr and Gastonia allows Pharr to assign the agreement to a
related entity such as SelKirk. Has that assignment been made in whole or in part? We need to know which entity is our
customer under that agreement and the SIU for several reasons. Also, since the SIU permit involves the privately owned
collection system, and we have ongoing efforts to take ownership of that system we need to know which entity you now
consider to be the owner of that system? Clarification on these points will help us better respond to the changes
requested for the SIU, ensure we are billing the correct customer under the SSSUA and properly complete any transfer
of the collection system to the City.
Thank you,
Charles L. Graham, Jr.
Assistant City Attorney
The City of Gastonia
P.O. Box 1748
Gastonia, NC 28053-1748
Phone: [phone]
Fax: [phone]
Email: [e-mail]
2

6/24/2021
Mail - Yitbarek, Diana - Outlook
[External] RE: NC0006033, Eagle Creek WWTP, City of Gastonia, Gaston County, MRO
Shellenbarger, David <[e-mail]>
Fri 6/18/2021 15:00
To: Yitbarek, Diana <[e-mail]>
Cc: Scheringer, Stephanie B<[e-mail]>; Templeton, Mike <[e-mail]>
I 1 attachments (98 KB)
Limits for Permit NC0004812.pdf;
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.
Diana,
The nutrient loads requested in Eagle Road's permit renewal application were supposed to be based on Pharr Yarn's allocation in NPDES permit NC0004812. The nitrogen was
calculated based on 1 MGD flow at 6 mg/L and phosphorus was based on 1 MGD flow at 1 mg/L. However, after getting a copy of Pharr Yarns' permit NC0004812, we see that is
not what is permitted for nitrogen.
Permit NC0004812 lists a total nitrogen limit of 27,397 Ibs/year and a total phosphorus limit of 3044 Ibs/year. We ask that these amounts be transferred to permit NC0006033
for Eagle Road WWTP. If the total nitrogen quantity needs to be broken down into season, we ask that it be divided proportionately according to days in the season (16,063
Ibs/summer and 11,334 Ibs/winter.)
Once again, thank you for your work on this permit. Please reach back out if there is anything else we can provide to you on this or anything else concerning the permit.
Thanks,
David Shellenbarger
Assistant Division Manager Compliance
Two Rivers Utilities
A
OUR MISSION: To provide fair, competent, responsive, cost-effective services at the highest level.
The City of Gastonia is committed to creating and maintaining a work environment that is inclusive, equitable and welcoming. We value diversity and promise to
honor your experiences, perspective and unique identity.
From: Yitbarek, Diana [mailto:[e-mail]]
Sent: Wednesday, June 16, 2021 11:26 AM
To: Shellenbarger, David <[e-mail]>
Cc: Templeton, Mike <[e-mail]>
Subject: NC0006033, Eagle Creek WWTP, City of Gastonia, Gaston County, MRO
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content
is safe.
Good morning, David
Apologies it took us some time to get back to you. Thanks for the clarification on NC0004812-Pharr Yarns' agreement and its connection to TRU's system -
no nutrient sales agreement is required.
We just noticed we need some clarification on Pharr Yarn's nutrient loads. In the NPDES renewal application, TRU requests that NPDES permit
NC0004812's allocation for 50 Ibs/day of TN and 8.3 Ibs/day of TP. We'll appreciate it if you provide the source document or TRU's calculation for this
nutrient allocation.
Thank you,
Best,
-Diana
Diana Yitbarek (she/her)
Engineer
T: 919-707-9130
diana.yitbareki5ncdenr.gai
NPDES Municipal Permitting Unit
NC Department of Environmental Quality) Division of Water Resources
Mailing: 1617 Mail Service Center, Raleigh, NC 27699-1617
Physical: 512 North Salisbury Street Raleigh NC 27604
*Please check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.
We can also be available via Microsoft Teams or other web -based calling services if requested. Thanks for your patience and stay safe.
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties.
https://outlook.office365.com/mail/inbox/id/AAQkADNmOTIxZjdhLTEyMWYtNDEzMS1 iOGNiLTkxNmZhYWJmZThIMAAQABC4pZBd8EdAi8ruopcXS%... 1/5

6/24/2021
Mail - Yitbarek, Diana - Outlook
From: Shellenbarger, David <[e-mail]>
Sent: Monday, May 10, 2021 10:38
To: Yitbarek, Diana <diana.yitbarekCancdenr.gov>
Cc: Templeton, Mike <[e-mail]>
Subject: [External] RE: NC0006033, Eagle Creek WWTP, City of Gastonia, Gaston County, MRO
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.
Diana:
The agreement is for transfer and treatment of Pharr Yarns/Selkirk Properties' wastewater. We were under the impression that if the wastewater flow from the discharger was
transferred and being treated by a utility, and the old discharge permit was rescinded, the nutrient allocation would then be transferrable to the entity treating the wastewater.
Accordingly we have not entered into a separate agreement with Pharr/Selkirk concerning the nutrient allocation. If this is not the case and an additional agreement is
necessary, please let us know as this will require significant time to get in place.
Thanks,
David Shellenbarger
Assistant Division Manager Compliance
Two Rivers Utilities
From: Yitbarek, Diana [mailto:[e-mail]]
Sent: Thursday, May 06, 2021 10:05 AM
To: Shellenbarger, David <[e-mail]>
Cc: Templeton, Mike <[e-mail]>
Subject: NC0006033, Eagle Creek WWTP, City of Gastonia, Gaston County, MRO
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content
is safe.
Good morning, David
Thank you for the information provided. I just noted that the document does not have an agreement regarding nutrient allocation. If I
understood correctly, the attached is an agreement for TRU to sell wastewater treatment services to Pharr Yarns, LLC (now, Selkirk
Properties, LLC). The rescinded Pharr Yarns' NPDES permit had a nutrient allocation, and TRU is requesting the nutrient allocation to be
added to the Eagle Road WWTP permit (NC0006033). We expect to see a completed agreement between the parties on the nutrient
allocation.
Mike - please correct me if I am wrong.
Thank you,
-Diana
From: Shellenbarger, David <davidsja tworiversutilities.com>
Sent: Friday, April 30, 2021 13:39
To: Yitbarek, Diana <[e-mail]>
Cc: Templeton, Mike <[e-mail]>
Subject: [External] RE: (request) RE: NC0006033, Eagle Creek WWTP, City of Gastonia, Gaston County, MRO
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.
Diana:
Thanks — Hope you are well as well.
Attached is the signed sewer agreement between Pharr Yarns and the City of Gastonia along with subsequent amendment and reassignment information.
Please let me know if you have any questions or concerns.
Thanks,
David
David Shellenbarger
Assistant Division Manager Compliance
Two Rivers Utilities
I cid:image004.png@O1 D703BC.8AEE7FAO
OUR MISSION: To provide fair, competent, responsive, cost-effective services at the highest level.
The City of Gastonia is committed to creating and maintaining a work environment that is inclusive, equitable and welcoming. We value diversity and promise to
honor your experiences, perspective and unique identity.
https://outlook.office365.com/mail/inbox/id/AAQkADNmOTIxZjdhLTEyMWYtNDEzMS1 iOGNiLTkxNmZhYWJmZThIMAAQABC4pZBd8EdAi8ruopcXS%... 2/5

6/24/2021 Mail - Yitbarek, Diana - Outlook
From: Yitbarek, Diana [mailto:[e-mail]]
Sent: Friday, April 30, 2021 12:32 PM
To: Shellenbarger, David <davids0tworiversutilities.com>
Cc: Templeton, Mike <mike.templetonl6 ncdenrgov>
Subject: (request) RE: NC0006033, Eagle Creek WWTP, City of Gastonia, Gaston County, MRO
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content
is safe.
Good afternoon, David
I hope this message finds you well. Two Rivers Utilities (TRU)'s August 1, 2019, renewal application cover letter requests that Pharr Yarns, LLC - NPDES
permit NC0004812's nutrient allocation be added to the NPDES permit NC0006033 for Eagle Road WWTP.
Please provide a copy of the signed agreement between TRU and Pharr Yarns, LLC.
Thank you and have a good weekend,
-Diana
Diana Yitbarek
Engineer
T: [phone]
[e-mail]
NPDES Municipal Permitting Unit
NC Department of Environmental Quality/ Division of Water Resources
Mailing: 1617 Mail Service Center, Raleigh, NC 27699-1617
Physical: 512 N. Salisbury Street Rm. 925T Raleigh NC 27604-1170
R'https://attach ments.office. net/owa/diana.yitbarek%40ncdenrgov/service.svc/s/GetAttachmentThumbnail?
id=AAMkADNmOTIxZjdhLTEyMWYtNDEzM51i0GN LTkxNmZhYWImZThIMABGAAAAAACbNtXPy901QbxVQ14DYFUBBwBXZLmYUZHgQ4ikbNYDUx2JAAAAAAEPAABXZLmYUZHgQ4ikbNYDUx2.1AACkZel1AAABEgACAAWK1s1.1
_A-9na7fCe311QItfRn6dMK7zdDvVj HjaA31MXptnxeAdkm9610u71rk_CTGpKSi HtRaZ6tM011jiBPIfRsigsKXSTbzZtfObRky07KgVMIG6z_ntxBwhzrlAnyl7TV W h1 LQWYwl_KyR5QvOwoOUxXBQvscCT5lnxY-8YJ FDSzdG 1g_tF2FI loaf
*Please check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email. We can also be available via Microsoft Teams if requested. Thanks fbr your patience
and stay safe.
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties.
From: Yitbarek, Diana <diana.yitbarek6tncdenrgov>
Sent: Thursday, April 15, 2021 14:09
To: Shellenbarger, David <[e-mail]>
Subject: Re: [External] RE: NC0006033, Eagle Creek WWTP, City of Gastonia, Gaston County, MRO
Thank you! Happy Thursday!
-Diana
Diana Yitbarek
Engineer
T: [phone]
[e-mail]
NPDES Municipal Permitting Unit
NC Department of Environmental Quality/ Division of Water Resources
Mailing: 1617 Mail Service Center, Raleigh, NC 27699-1617
Physical: 512 N. Salisbury Street Rm. 925T Raleigh NC 27604-1170
https://attachments.office.net/owa/diana.yitbarek%4Oncdenr.gov/service. svc/s/GetAttachmentThumbnail?
i d=AAMkADNmo TlxZj dhLTEyM W YtNDEzM S 1 iOGNiLTkxNmZhY W Jm2ThIMABGA A A A A ACbNtXPy901 Qbx V Q14DYFUB BwBXZLmYUZHgQ4ikbNYDUx2JA A A A A AEPAABXZLmYUZHgQ4 ikbNYDUx2 J
_A-9na7fCe3JIQltfRn6dMK7zdDvVjHjaA31 MXptnxeAdkm9610u71 rk_CTGpK5iHtBaZ6tM01 Jj iBPIfRsIgsKX5TbzZtfObRkyQ7KgVMIG6z_ntx6whzrlAny17TV WhILQWYw1_KyPSQvOwoOUxXBQvscCTSInxY-BYJF
*Please check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email. We can also be available via Microsoft Teams if requested. Thanks for your patience
and stay safe.
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties.
From: Shellenbarger, David <davidstatworiversutilities.com>
Sent: Thursday, April 15, 2021 14:04
To: Yitbarek, Diana <[e-mail]>
Subject: RE: [External] RE: NC0006033, Eagle Creek WWTP, City of Gastonia, Gaston County, MRO
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to B&port Spam.
Diana:
Sorry that didn't work. Here's a PDF version.
Thanks,
David
David Shellenbarger
Assistant Division Manager Compliance
https://outlook.office365.com/mail/inbox/id/AAQkADNmOTIxZjdhLTEyMWYtNDEzMS1 iOGNiLTkxNmZhYWJmZThIMAAQABC4pZBd8EdAi8ruopcXS%... 3/5

6/24/2021 Mail - Yitbarek, Diana - Outlook
Two Rivers Utilities
GI'cid:image004.png@O1 D703BC.8AEE7FAO
OUR MISSION: To provide fair, competent, responsive, cost-effective services at the highest level.
The City of Gastonia is committed to creating and maintaining a work environment that is inclusive, equitable and welcoming. We value diversity and promise to
honor your experiences, perspective and unique identity.
From: Yitbarek, Diana [mailto:[e-mail]]
Sent: Thursday, April 15, 2021 1:58 PM
To: Shellenbarger, David <[e-mail]>
Subject: Re: [External] RE: NC0006033, Eagle Creek WWTP, City of Gastonia, Gaston County, MRO
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content
is safe.
David - I have issues opening the file: 2. Second Species Aquatic Toxicity for June 2018.xps
Could you please convert it to pdf and resend it?
Thank you,
-Diana
Diana Yitbarek
Engineer
T: [phone]
[e-mail]
NPDES Municipal Permitting Unit
NC Department of Environmental Quality/ Division of Water Resources
Mailing: 1617 Mail Service Center, Raleigh, NC 27699-1617
Physical: 512 N. Salisbury Street Rm. 925T Raleigh NC 27604-1170
khttps://attach ments.office. net/owa/dianavitbarek%40ncdencgov/service.svc/s/GetAttachmentThumbnail?
id=AAMkADNmOTIxZjdhLTEyMWYtNDEzMS1i0GN LTkxNmZhYWJmZThIMABGAAAAAACbNtXPy901QbxVQ14DYFUBBwBXZLmYUZHgQ4ikbNYDUx2JAAAAAAEPAABXZLmYUZHgQ4ikbNYDUx2.1AACkle11AAABEgAQAMx1BgNI
_A-9na7fCe311QItfRn6dMK7zdDvVj HjaA31MXptnxeAdkm9610u71rk_CTGpKSi HtBaZ6tMO1JjiBPIfRsIgsKXSTbzZtfObRkyQ7KgVMIG6z_ntxBwhzrlAnyl7TV W hILQWYwl_KyPSQvOwoOUxXBQvscCT5lnxY-8YJ FDSzdG lg_tF2Fl loaf
*Please check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email. We can also be available via Microsoft Teams if requested. Thanks for your patience
and stay safe.
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties.
From: Yitbarek, Diana <[e-mail]>
Sent: Thursday, April 15, 2021 13:51
To: Shellenbarger, David <[e-mail]>
Subject: Re: [External] RE: NC0006033, Eagle Creek WWTP, City of Gastonia, Gaston County, MRO
Good afternoon, David - Thank you for the information provided. I will let you know if we have any questions upon review.
Best,
Diana Yitbarek
Engineer
T: [phone]
diana.yitbarek(ancdenr.gov
NPDES Municipal Permitting Unit
NC Department of Environmental Quality/ Division of Water Resources
Mailing: 1617 Mail Service Center, Raleigh, NC 27699-1617
Physical: 512 N. Salisbury Street Rm. 925T Raleigh NC 27604-1170
Rhttps://attach ments.office. net/owa/diana.yitbarek%40ncdencgov/service.svc/s/GetAttachmentThumbnail?
id=AAMkADNmOTIxZjdhLTEyM WYtN DEzMS1i0GN ILTkxNmZhYWJ mZThIMABGAAAAAACbNtXPy901QbxVQ14DYFU BBwBXZLmYUZHgQ4ikbNYDUx2JAAAAAAEPAABXZLmYUZHgQ4ikbNYDUx2JAACkleJIAAABEgA0AMx1BqNI
_A-9na7fCe311QItfRn6dMK7zdDvVj HjaA31MXptnxeAdkm9610u71rk_CTGpKSi HtBaZ6tM01JjiBPIfRsIgsKXSTbzZtfObRkyQ7KgVMIG6z_ntxBwhzrlAnyl7TVW hI LQWYw1_KyPSQvOwoOUxXBQvscCT5lnxY-8YJ FDSzdG lg_tF2FIloBf
*Please check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email. We can also be available via Microsoft Teams if requested. Thanks for your patience
and stay safe.
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties.
From: Shellenbarger, David <[e-mail]>
Sent: Thursday, April 15, 2021 11:35
To: Yitbarek, Diana <diana.yitbarek(c9ncdenr.gov>
Cc: Scheringer, Stephanie B<[e-mail]>; Barker, Doug <dougttworiversutilities.com>• Starnes, Justin <[e-mail]>
Subject: [External] RE: NC0006033, Eagle Creek WWTP, City of Gastonia, Gaston County, MRO
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.
Ms. Yitbarek:
Thank you for your work reviewing our permit application. Please see the attached responses regarding the information requested.
Requested Information:
https://outlook.office365.com/mail/inbox/id/AAQkADNmOTIxZjdhLTEyMWYtNDEzMS1 iOGNiLTkxNmZhYWJmZThIMAAQABC4pZBd8EdAi8ruopcXS%... 4/5

6/24/2021 Mail - Yitbarek, Diana - Outlook
1. Please provide the signed Effluent Pollutant Scans for 2017, 2018, and 2019.
Response: Priority pollutant scans were collected in June 2017, September 2018, and March 2019. Copies of the submitted PPA reports are
attached.
2. The permit for this facility requires four toxicity tests for a test organism other than Ceriodaphnia. In our database, we have records of three 2nd
species tests (9/2018, 12/2018, and 3/2019). Please let me know what you have in your records.
Response: Four 2nd species tests (pimephales promelas) were collected in June, September and December 2018; and March 2019. A copy of the
AT-5 report submitted for June 2018 is attached.
1. Please complete this form to meet the latest application requirements for the updated application form.
Response: The completed short form is attached.
2. Please provide coordinates for the upstream and downstream location points (approximate coordinates to the actual location from an online map
would suffice).
Response: Coordinates of the creek sample locations for Eagle Road WWTP are as follows:
Upstream 35.235811, -81.066120 (35° 14' 8.9" N, -81° 3' 58.0"W)
Downstream 35.220307, -81.064113 (35° 13' 13.1" N, -81° 3' 50.8" W)
3. Please provide the last industrial waste survey (IWS) conducted for the Eagle Creek WWTP service area. If no IWS has been carried out, a list of the
service area industries with their SIC codes will suffice.
a. Alternatively, please provide a map that depicts the service area if the industrial list is not available.
Response: An industrial waste survey was completed in June 2020 for the entire area covered by the City of Gastonia's three wastewater
treatment plants. A copy of this survey is attached.
It is not easy to tell which WWTP the industries in the IWS discharge to. None of the industrial customers in Two Rivers Utilities' service area
discharge into Eagle Road WWTP. One industry in the City of Belmont (Syncot Fibers and Plastics - SIC Code 2299) discharges into Eagle Road.
Syncot Fibers and Plastics is regulated through the City of Belmont's pretreatment program and is not permitted as an SIU.
4. If there are additional pollutants with certified methods to be reported, please submit this Chemical Addendum.
Response: Information for all pollutants analyzed by certified methods have been reported on eDMRs or PPA forms and summarized in this renewal
application. There are no additional pollutants to report.
Please let us know if you have any questions or concerns with any of these items or if there is anything else we can provide regarding this renewal.
Thanks,
David Shellenbarger
Assistant Division Manager Compliance
Two Rivers Utilities
G:cid:image004.png@O1 D703BC.8AEE7FAO
OUR MISSION: To provide fair, competent, responsive, cost-effective services at the highest level.
The City of Gastonia is committed to creating and maintaining a work environment that is inclusive, equitable and welcoming. We value diversity and promise to
honor your experiences, perspective and unique identity.
From: Yitbarek, Diana Imailto:[e-mail]]
Sent: Wednesday, March 31, 20215:14 PM
To: Shellenbarger, David <davidsPtworiversutilities.com>
Subject: NC0006033, Eagle Creek WWTP, City of Gastonia, Gaston County, MRO
Good afternoon, David
I am the assigned permit writer for the subject line facility. I look forward to working with you to complete this permit renewal. Thanks for submitting the
August 1, 2019, NPDES permit application for renewal. I will appreciate your support with some additional information to address the following comments:
1. Please provide the signed Effluent Pollutant Scans for 2017, 2018, and 2019.
2. The permit for this facility requires four toxicity tests for a test organism other than Ceriodaphnia. In our database, we have records of three 2nd
species tests (9/2018, 12/2018, and 3/2019). Please let me know what you have in your records.
3. Please complete this form to meet the latest application requirements for the updated application form 2A.
4. Please provide coordinates for the upstream and downstream location points (approximate coordinates to the actual location from an online map
would suffice).
5. Please provide the last industrial waste survey (IWS) conducted for the Eagle Creek WWTP service area. If no IWS has been carried out, a list of the
service area industries with their SIC codes will suffice.
a. Alternatively, please provide a map that depicts the service area if the industrial list is not available.
6. If there are additional pollutants with certified methods to be reported, please submit this Chemical Addendum.
I will set a due date of April 23, 2021, but if you need more time, just let me know.
Please let me know if you have any questions.
-Diana
Diana Yitbarek
Engineer
T: [phone]
[e-mail]
NPDES Municipal Permitting Unit
NC Department of Environmental Quality) Division of Water Resources
Mailing: 1617 Mail Service Center, Raleigh, NC 27699-1617
Physical: 512 N. Salisbury Street Rm. 925T Raleigh NC 27604-1170
;1,cid: image003.j pg@O1D73125.A32941E0
`Please check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email. We can also be available via Microsoft Teams if requested. Thanks for your patience
and stay safe.
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties.
https://outlook.office365.com/mail/inbox/id/AAQkADNmOTIxZjdhLTEyMWYtNDEzMS1 iOGNiLTkxNmZhYWJmZThIMAAQABC4pZBd8EdAi8ruopcXS%... 5/5

4/15/2021 Mail - Yitbarek, Diana - Outlook
[External] RE: NC0006033, Eagle Creek WWTP, City of Gastonia, Gaston County, MRO
Shellenbarger, David <[e-mail]>
Thu 4/15/2021 11:37
To: Yitbarek, Diana <[e-mail]>
Cc: Scheringer, Stephanie B<[e-mail]>; Barker, Doug <[e-mail]>; Starnes,
Justin <[e-mail]>
0 6 attachments (9 MB)
1. PPA - 2017 06 EG .pdf; 1. PPA - 2018 09 EG .pdf; 1. PPA - 2019 03 EG .pdf; 2. Second Species Aquatic Toxicity for June 2018.xps;
3. Completed Short Form.pdf; 5. IWS Report - Two Rivers Utilities.pdf;
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment
to Report Spam.
Ms. Yitbarek:
Thank you for your work reviewing our permit application. Please see the attached responses
regarding the information requested.
Requested Information:
1. Please provide the signed Effluent Pollutant Scans for 2017, 2018, and 2019.
Response: Priority pollutant scans were collected in June 2017, September 2018, and March
2019. Copies of the submitted PPA reports are attached.
2. The permit for this facility requires four toxicity tests for a test organism other than
Ceriodaphnia. In our database, we have records of three 2nd species tests (9/2018,
12/2018, and 3/2019). Please let me know what you have in your records.
Response: Four 2nd species tests (pimephales promelas) were collected in June, September
and December 2018; and March 2019. A copy of the AT-5 report submitted for June 2018 is
attached.
3. Please complete this form to meet the latest application requirements for the updated
application form.
Response: The completed short form is attached.
4. Please provide coordinates for the upstream and downstream location points (approximate
coordinates to the actual location from an online map would suffice).
Response: Coordinates of the creek sample locations for Eagle Road WWTP are as follows:
Upstream 35.235811, -81.066120 (35° 14' 8.9" N, -81° 3' 58.0"W)
Downstream 35.220307, -81.064113 (35° 13' 13.1" N, -81° 3' 50.8" W)
5. Please provide the last industrial waste survey (IWS) conducted for the Eagle Creek WWTP
service area. If no IWS has been carried out, a list of the service area industries with their SIC
codes will suffice.
a. Alternatively, please provide a map that depicts the service area if the industrial list is
not available.
Response: An industrial waste survey was completed in June 2020 for the entire area
covered by the City of Gastonia's three wastewater treatment plants. A copy of this survey is
attached.
It is not easy to tell which WWTP the industries in the IWS discharge to. None of the
industrial customers in Two Rivers Utilities' service area discharge into Eagle Road WWTP.
One industry in the City of Belmont (Syncot Fibers and Plastics — SIC Code 2299) discharges
https://outlook.office.com/mail/inbox/id/AAQkADNm IxZjdhLTEyMWYtNDEzMS1iOGNILTkxNmZhYWJmZThIMAAQAAgdL%2BomJptCnNGVZrkXIiU... 1/3

4/15/2021 Mail - Yitbarek, Diana - Outlook
into Eagle Road. Syncot Fibers and Plastics is regulated through the City of Belmont's
pretreatment program and is not permitted as an SIU.
6. If there are additional pollutants with certified methods to be reported, please submit this
Chemical Addendum.
Response: Information for all pollutants analyzed by certified methods have been reported
on eDMRs or PPA forms and summarized in this renewal application. There are no additional
pollutants to report.
Please let us know if you have any questions or concerns with any of these items or if there is anything else we
can provide regarding this renewal.
Thanks,
David Shellenbarger
Assistant Division Manager Compliance
Two Rivers Utilities
(;\SlC)NII
OUR MISSION: To provide fair, competent, responsive, cost-effective services at the highest level.
The City of Gastonia is committed to creating and maintaining a work environment that is inclusive,
equitable and welcoming. We value diversity and promise to honor your experiences, perspective and
unique identity.
From: Yitbarek, Diana [mailto:[e-mail]]
Sent: Wednesday, March 31, 2021 5:14 PM
To: Shellenbarger, David <[e-mail]>
Subject: NC0006033, Eagle Creek WWTP, City of Gastonia, Gaston County, MRO
Good afternoon, David
I am the assigned permit writer for the subject line facility. I look forward to working with you to
complete this permit renewal. Thanks for submitting the August 1, 2019, NPDES permit application
for renewal. I will appreciate your support with some additional information to address the following
comments:
1. Please provide the signed Effluent Pollutant Scans for 2017, 2018, and 2019.
2. The permit for this facility requires four toxicity tests for a test organism other than
Ceriodaphnia. In our database, we have records of three 2nd species tests (9/2018, 12/2018,
and 3/2019). Please let me know what you have in your records.
3. Please complete this form to meet the latest application requirements for the updated
application form 2A.
4. Please provide coordinates for the upstream and downstream location points (approximate
coordinates to the actual location from an online map would suffice).
5. Please provide the last industrial waste survey (IWS) conducted for the Eagle Creek WWTP
service area. If no IWS has been carried out, a list of the service area industries with their SIC
codes will suffice.
https://outlook.office.com/mail/inbox/id/AAQkADNm IxZjdhLTEyMWYtNDEzMS1iOGNILTkxNmZhYWJmZThIMAAQAAgdL%2BomJptCnNGVZrkXIiU... 2/3

4/15/2021 Mail - Yitbarek, Diana - Outlook
a. Alternatively, please provide a map that depicts the service area if the industrial list is
not available.
6. If there are additional pollutants with certified methods to be reported, please submit this
Chemical Addendum.
I will set a due date of April 23, 2021, but if you need more time, just let me know.
Please let me know if you have any questions.
-Diana
Diana Yitbarek
Engineer
T: [phone]
[e-mail]
NPDES Municipal Permitting Unit
NC Department of Environmental Quality/ Division of Water Resources
Mailing: 1617 Mail Service Center, Raleigh, NC 27699-1617
Physical: 512 N. Salisbury Street, Rm. 925T, Raleigh, NC 27604-1170
Q44pkjAr i1 UN rII
*Please check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email. We can
also be available via Microsoft Teams if requested. Thanks for your patience and stay safe.
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties.
https://outlook.office.com/mail/inbox/id/AAQkADNm IxZjdhLTEyMWYtNDEzMS1iOGNILTkxNmZhYWJmZThIMAAQAAgdL%2BomJptCnNGVZrkXIiU... 3/3

Permit No. NC0006033
NPDES Implementation of Instream Dissolved Metals Standards - Freshwater Standards
The NC 2007-2015 Water Quality Standard (WQS) Triennial Review was approved by the NC
Environmental Management Commission (EMC) on November 13, 2014. The US EPA subsequently
approved the WQS revisions on April 6, 2016, with some exceptions. Therefore, metal limits in draft
permits out to public notice after April 6, 2016 must be calculated to protect the new standards - as
approved.
Table 1. NC Dissolved Metals Water Quality Standards/Aquatic Life Protection
Parameter
Acute FW, µg/1
(Dissolved)
Chronic FW, µg/1
(Dissolved)
Acute SW, µg/1
(Dissolved)
Chronic SW, µg/1
(Dissolved)
Arsenic
340
150
69
36
Beryllium
65
6.5
---
---
Cadmium
Calculation
Calculation
40
8.8
Chromium III
Calculation
Calculation
---
---
Chromium VI
16
11
1100
50
Copper
Calculation
Calculation
4.8
3.1
Lead
Calculation
Calculation
210
8.1
Nickel
Calculation
Calculation
74
8.2
Silver
Calculation
0.06
1.9
0.1
Zinc
Calculation
Calculation
90
81
Table 1 Notes:
1. FW= Freshwater, SW= Saltwater
2. Calculation = Hardness dependent standard
3. Only the aquatic life standards listed above are expressed in dissolved form. Aquatic life
standards for Mercury and selenium are still expressed as Total Recoverable Metals due to
bioaccumulative concerns (as are all human health standards for all metals). It is still necessary
to evaluate total recoverable aquatic life and human health standards listed in 15A NCAC
2B.0200 (e.g., arsenic at 10 µg/1 for human health protection; cyanide at 5 µg/L and fluoride at
1.8 mg/L for aquatic life protection).
Table 2. Dissolved Freshwater Standards for Hardness -Dependent Metals
The Water Effects Ratio (WER) is equal to one unless determined otherwise under 15A
NCAC 02B .0211 Subparagraph (11)(d)
Metal
NC Dissolved Standard, µg/I
Cadmium, Acute
WER*{1.136672-[ln hardness](0.041838)} • e^{0.9151 [In hardness]-3.1485}
Cadmium, Acute Trout waters
WER*{1.136672-[ln hardness](0.041838)} • e^{0.9151[ln hardness]-3.6236}
Cadmium, Chronic
WER*{1.101672-[ln hardness](0.041838)} • e^{0.7998[ln hardness]-4.4451}
Chromium III, Acute
WER*0.316 • e^{0.8190[ln hardness]+3.7256}
Chromium III, Chronic
WER*0.860 • e^{0.8190[ln hardness]+0.6848}
Copper, Acute
WER*0.960 • e^{0.9422[ln hardness]-1.700}
Copper, Chronic
WER*0.960 • e^ {0.8545 [In hardness]-1.702}
Lead, Acute
WER*{1.46203-[ln hardness](0.145712)} • e^{1.273[In hardness]-1.460}
Lead, Chronic
WER*{1.46203-[ln hardness](0.145712)} • e^{1.273[In hardness]-4.705}
Nickel, Acute
WER*0.998 • e^{0.8460[ln hardness]+2.255}
Nickel, Chronic
WER*0.997 • e^{0.8460[ln hardness]+0.0584}
Page 1 of 4

Permit No. NC0006033
Silver, Acute
WER*0.85 - e^{1.72[ln hardness]-6.59}
Silver, Chronic
Not applicable
Zinc, Acute
WER*0.978 - e^{0.8473[ln hardness]+0.884}
Zinc, Chronic
WER*0.986 . e^{0.8473[ln hardness]+0.884}
General Information on the Reasonable Potential Analysis (RPA)
The RPA process itself did not change as the result of the new metals standards. However, application of
the dissolved and hardness -dependent standards requires additional consideration in order to establish the
numeric standard for each metal of concern of each individual discharge.
The hardness -based standards require some knowledge of the effluent and instream (upstream) hardness
and so must be calculated case -by -case for each discharge.
Metals limits must be expressed as `total recoverable' metals in accordance with 40 CFR 122.45(c). The
discharge -specific standards must be converted to the equivalent total values for use in the RPA
calculations. We will generally rely on default translator values developed for each metal (more on that
below), but it is also possible to consider case -specific translators developed in accordance with
established methodology.
RPA Permitting Guidance/WQBELs for Hardness -Dependent Metals - Freshwater
The RPA is designed to predict the maximum likely effluent concentrations for each metal of concern,
based on recent effluent data, and calculate the allowable effluent concentrations, based on applicable
standards and the critical low -flow values for the receiving stream.
If the maximum predicted value is greater than the maximum allowed value (chronic or acute), the
discharge has reasonable potential to exceed the standard, which warrants a permit limit in most cases. If
monitoring for a particular pollutant indicates that the pollutant is not present (i.e. consistently below
detection level), then the Division may remove the monitoring requirement in the reissued permit.
1. To perform a RPA on the Freshwater hardness -dependent metals the Permit Writer compiles the
following information:
• Critical low flow of the receiving stream, 7Q10 (the spreadsheet automatically calculates
the 1Q10 using the formula 1Q10 = 0.843 (s7Q10, cfs) 0.993
• Effluent hardness and upstream hardness, site -specific data is preferred
• Permitted flow
• Receiving stream classification
2. In order to establish the numeric standard for each hardness -dependent metal of concern and for
each individual discharge, the Permit Writer must first determine what effluent and instream
(upstream) hardness values to use in the equations.
The permit writer reviews DMR's, Effluent Pollutant Scans, and Toxicity Test results for any
hardness data and contacts the Permittee to see if any additional data is available for instream
hardness values, upstream of the discharge.
If no hardness data is available, the permit writer may choose to do an initial evaluation using a
default hardness of 25 mg/L (CaCO3 or (Ca + Mg)) Minimum and maximum limits on the
hardness value used for water quality calculations are 25 mg/L and 400 mg/L, respectively.
If the use of a default hardness value results in a hardness -dependent metal showing reasonable
potential, the permit writer contacts the Permittee and requests 5 site -specific effluent and
upstream hardness samples over a period of one week. The RPA is rerun using the new data.
Page 2 of 4

Permit No. NC0006033
The overall hardness value used in the water quality calculations is calculated as follows:
Combined Hardness (chronic)
= (Permitted Flow, cfs *Avg. Effluent Hardness, mg/L) + (s7Q10, cfs *Avg. Upstream Hardness, mg/L)
(Permitted Flow, cfs + s7Q10, cfs)
The Combined Hardness for acute is the same but the calculation uses the 1 Q 10 flow.
3. The permit writer converts the numeric standard for each metal of concern to a total recoverable
metal, using the EPA Default Partition Coefficients (DPCs) or site -specific translators, if any
have been developed using federally approved methodology.
EPA default partition coefficients or the "Fraction Dissolved" converts the value for
dissolved metal at laboratory conditions to total recoverable metal at in -stream
ambient conditions. This factor is calculated using the linear partition coefficients
found in The Metals Translator: Guidance for Calculating a Total Recoverable
Permit Limit from a Dissolved Criterion (EPA 823-B-96-007, June 1996) and the
equation:
Cdiss = 1
Ctotal 1 + { [Kpo] [SS('+a>] [10-6] }
Where:
ss = in -stream suspended solids concentration [mg/1], minimum of 10 mg/L used,
and
Kpo and a = constants that express the equilibrium relationship between dissolved
and adsorbed forms of metals. A list of constants used for each hardness -dependent
metal can also be found in the RPA program under a sheet labeled DPCs.
4. The numeric standard for each metal of concern is divided by the default partition coefficient (or
site -specific translator) to obtain a Total Recoverable Metal at ambient conditions.
In some cases, where an EPA default partition coefficient translator does not exist (ie. silver), the
dissolved numeric standard for each metal of concern is divided by the EPA conversion factor to
obtain a Total Recoverable Metal at ambient conditions. This method presumes that the metal is
dissolved to the same extent as it was during EPA's criteria development for metals. For more
information on conversion factors see the June, 1996 EPA Translator Guidance Document.
5. The RPA spreadsheet uses a mass balance equation to determine the total allowable concentration
(permit limits) for each pollutant using the following equation:
Ca = (s7Q10 + Qw) (Cwqs) — (s7Q10) (Cb)
Qw
Where: Ca = allowable effluent concentration (µg/L or mg/L)
Cwqs = NC Water Quality Standard or federal criteria (µg/L or mg/L)
Cb = background concentration: assume zero for all toxicants except NH3* (µg/L or mg/L)
Qw = permitted effluent flow (cfs, match s7Q10)
s7Q 10 = summer low flow used to protect aquatic life from chronic toxicity and human
health through the consumption of water, fish, and shellfish from noncarcinogens (cfs)
* Discussions are on -going with EPA on how best to address background concentrations
Flows other than s7Q 10 may be incorporated as applicable:
1 Q 10 = used in the equation to protect aquatic life from acute toxicity
Page 3 of 4

Permit No. NC0006033
QA = used in the equation to protect human health through the consumption of water,
fish, and shellfish from carcinogens
30Q2 = used in the equation to protect aesthetic quality
6. The permit writer enters the most recent 2-3 years of effluent data for each pollutant of concern.
Data entered must have been taken within four and one-half years prior to the date of the permit
application (40 CFR 122.21). The RPA spreadsheet estimates the 95th percentile upper
concentration of each pollutant. The Predicted Max concentrations are compared to the Total
allowable concentrations to determine if a permit limit is necessary. If the predicted max exceeds
the acute or chronic Total allowable concentrations, the discharge is considered to show
reasonable potential to violate the water quality standard, and a permit limit (Total allowable
concentration) is included in the permit in accordance with the U.S. EPA Technical Support
Document for Water Quality -Based Toxics Control published in 1991.
7. When appropriate, permit writers develop facility specific compliance schedules in accordance
with the EPA Headquarters Memo dated May 10, 2007 from James Hanlon to Alexis Strauss on
40 CFR 122.47 Compliance Schedule Requirements.
8. The Total Chromium NC WQS was removed and replaced with trivalent chromium and
hexavalent chromium Water Quality Standards. As a cost savings measure, total chromium data
results may be used as a conservative surrogate in cases where there are no analytical results
based on chromium III or VI. In these cases, the projected maximum concentration (95th %) for
total chromium will be compared against water quality standards for chromium III and
chromium VI.
9. Effluent hardness sampling and instream hardness sampling, upstream of the discharge, are
inserted into all permits with facilities monitoring for hardness -dependent metals to ensure the
accuracy of the permit limits and to build a more robust hardness dataset.
10. Hardness and flow values used in the Reasonable Potential Analysis for this permit included:
Parameter
Value
Comments (Data Source)
Average Effluent Hardness (mg/L)
[Total as, CaCO3 or (Ca+Mg)]
42.05
Data provided in DMRs
Average Upstream Hardness (mg/L)
[Total as, CaCO3 or (Ca+Mg)]
25.31
Data provided in DMRs
7Q10 summer (cfs)
125.0
NPDES Files
1Q10 (cfs)
101.9
Calculated in RPA
Permitted Flow (MGD)
4.0
NPDES permit application
Date: 4/26/2021
Permit Writer: Diana Yitbarek
Page 4 of 4

NORTH CAROLINA 2020 303(D) LIST
Upper Catawba Catawba River Basin
AU Name AU Number Classification Length or Area Units
AU ID Description
Isaac Creek 11-59-(2) WS-IV,B;CA FW Miles
1175 From a point 0.6 mile upstream of mouth to Lake Hickory, Catawba River
PARAMETER IR CATEGORY CRITERIA STATUS REASON FOR RATING 303D YEAR
pH (6 su, AL, FW) 5 Exceeding Criteria Legacy RAMS Assessments
Falling Creek 11-60 C FW Miles
1178 From source to Lake Hickory, Catawba River
PARAMETER
IR CATEGORY CRITERIA STATUS REASON FOR RATING 303D YEAR
Benthos (Nar, AL, FW)
5 Exceeding Criteria Fair, Poor or Severe Bioclassification 2010
Lower Little River 11-69-(0.5)b C i FW Miles
13612 From Lambert Fork to a point 0.5 mile upstream of mouth of Stirewalt Creek
PARAMETER
IR CATEGORY CRITERIA STATUS REASON FOR RATING 303D YEAR
Fish Community (Nar, AL, FW)
Muddy Fork
1204 From source to SR 1409
5 Exceeding Criteria Fair, Poor or Severe Bioclassification
11-69-4 C FW Miles
PARAMETER
IR CATEGORY CRITERIA STATUS REASON FOR RATING 303D YEAR
Benthos (Nar, AL, FW)
5 Exceeding Criteria Fair, Poor or Severe Bioclassification
McLin Creek 11-76-5-(3) WS-IV;CA
1254 From a point 0.2 mile upstream of Catawba County SR 1722 to Lyle Creek
0.7 FW Miles
PARAMETER
IR CATEGORY CRITERIA STATUS REASON FOR RATING 303D YEAR
Benthos (Nar, AL, FW)
5 Exceeding Criteria Fair, Poor or Severe Bioclassification
Catawba River Basin
03050102 South Fork Catawba
South Fork Catawba River 11-129-(15.5) WS-V 18.1 FW Miles
453 From a point 0.4 mile upstream of Long Creek to Cramerton Dam and Lake Wylie at Upper Armstrong
Bridge
PARAMETER
IR CATEGORY CRITERIA STATUS REASON FOR RATING 303D YEAR
Turbidity (50 NTU, AL, FW miles)
Mauney Creek
497 From source to Hoyle Creek
PARAMETER IR CATEGORY CRITERIA STATUS REASON FOR RATING 303D YEAR
Benthos (Nar, AL, FW) 5 Exceeding Criteria Fair, Poor or Severe Bioclassification
5 Exceeding Criteria Exceeding Criteria with Statistical 2008
Confidence
11-129-15-5 WS-IV 4.4 FW Miles
7/21/2021 NC 2020 303d List- Approved by EPA June 23,2021
Page 35 of 188

ROY COOPER.
Governor
ELIZABETH S. BISER
Secretary
S. DANIEL SMITH
Director
MEMORANDUM
To:
NORTH CAROLINA
Environmental Quality
September 7, 2021
Clinton Cook
NC DEQ / DWR / Public Water Supply
Mooresville Regional Office
From: Diana Yitbarek
NC DEQ / DWR / Municipal Permitting Unit
Subject: Review of Draft NPDES Permit NC0006033
Eagle Road WWTP
Outfall 001/ South Fork Catawba River
Gaston County
Please indicate below your agency's position or viewpoint on the draft permit and return this form by
October 7, 2021. If you have any questions on the draft permit, please contact me at 919-707-9130 or
via e-mail [[e-mail]].
RESPONSE: (Check one)
X
§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§
Concur with the issuance of this permit provided the facility is operated and maintained properly,
the stated effluent limits are met prior to discharge, and the discharge does not contravene the
designated water quality standards.
Concurs with issuance of the above permit, provided the following conditions are met: *
*I have no appreciable expertise in implementation of the Clean Water Act requirements and have
minimal understanding of the information provided. As a result, I have no basis for opposing the permit.
Opposes the issuance of the above permit, based on reasons stated below, or attached:
Signature: t2 C 4— Date: September 17, 2021
NORTH Cnt of En NA
rh�weM o� �ironmemai Oualii`
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 11617 Mail Service Center I Raleigh, North Carolina 27699-1617
919.707.9000

LOCALiQ
StarNews I The Dispatch I Times -News
Sun Journal I The Daily News I The Star
The Free Press I Gaston Gazette
PROOF OF PUBLICATION
Ncdenr-Div. Of Water Resources
Ncdenr-Div. Of Water Resources
1617 MAIL SERVICE CENTER
RALEIGH NC 27699
STATE OF NORTH CAROLINA, COUNTY OF GASTON
The Gaston Gazette, a newspaper printed and published in the city
of Gastonia, and of general circulation in the County of Gaston,
State of North Carolina, and personal knowledge of the facts
herein state and that the notice hereto annexed was Published in
said newspapers in the issue dated:
09/09/2021
and that the fees charged are legal.
Sworn to and subscribed before on 09/09/2021
Legal Clerk
uz(
Notary, State ofJW1, County of Wn
My commision expires
Publication Cost: $156.40
Order No: 6270241
Customer No: 489035
PO #:
THIS IS NOT AN INVOICE!
Please do not use this form for payment remittance.
SA FAfi BERTELSEN
Notary Public
State of Wisconsin
# of Copies:
1
PO Box 631245 Cincinnati, OH 45263-1245
Public Notice
North Carolina Environmen-
tal Management Commis-
sion/NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Notice of Intent to Issue a
NPDES Wastewater Permit
NC0020184 Long Creek
WWTP, and NC0006033 Eagle
Road WWTP
The North Carolina Environ-
mental Management
Commission proposes to
issue a NPDES wastewater
discharge permit to the
person(s) listed below. Writ-
ten comments regarding the
proposed permit will be
accepted until 30 days after
the publish date of this
notice. The Director of the
NC Division of Water
Resources (DWR) may hold
a public hearing should there
be a significant degree of
public interest. Please mail
comments and/or informa-
tion requests to DWR at the
above address. Interested
persons may visit the DWR
at 512 N. Salisbury Street,
Raleigh, NC 27604 to review
information on file. Addi-
tional information on NPDES
permits and this notice may
be found on our website:
http://deq.nc.gov/about/divisi
ons/water-resources/water-
resources-perm i ts/waste-
water-branch/npdes-waste-
water/public-notices,or by
calling [phone]. The
City of Gastonia (P.O. Box
1748, Gastonia, NC 2B053) has
requested renewal of the
NPDES Permit N00020184
and NC0006033 for its Waste-
water Treatment Plants in
Gaston County. These
permitted facilities
discharges treated domestic
and pretreated industrial
wastewater to South Fork in
the Catawba River Basin.
Ammonia, biochemical
oxygen demand, dissolved
oxygen, fecal coliform, pH,
total residual chlorine, total
nitrogen, total phosphorous,
and total suspended solids
are water quality limited
parameters in both permits.
These discharges may affect
future allocations in these
segments of the South Fork
Catawba River.
6270241
Page 1 of 1

The Division received comments for the Eagle Road WWTP (NC0006033) NPDES Draft Permit Renewal
and provides the following responses:
Comments from Two Rivers Utilities (TRU):
1. Comment on Total Phosphorous (TP) concentration limit
"The draft permit lists a monthly effluent limit for TP of 1.0 mg/L. The fact sheet states that this limit had
been in effect and is continuing; however, in the current permit the total phosphorus concentration limit
ended on 12/31/2017 (when the mass load limit took effect) and only monitoring and reporting is
currently required regarding the total phosphorus concentration. The removal of this limit is also
documented in section 6.7 of the permit's Fact Sheet and is consistent with the manner in which the
allocations are described as being expressed in this section of the Fact Sheet. The City of Gastonia strongly
requests that this monthly average limit be removed and that the phosphorus allocation continues to be
expressed solely as a mass load limit."
Response:
The NPDES permit, effective on April 1, 2017, set up a TP concentration limit to end on December 31,
2017. The TP concentration limit was in effect in previous NPDES permits for this Facility and was removed
per TRU's request. Upon reviewing the 1995 Lake Wylie Total Maximum Daily Load (TMDL) permitting
strategy and its recommended monthly average limit of 1.0 mg/I for TP, the Division reviewed the current
data projected for the full design flow and has decided not to reinstate the concentration limit. The Lake
Wylie permittees have focused on mass limits, which are acceptable under the TMDL. Therefore, the
Division has determined to maintain the decision from the previous permit cycle.
2. Comment on Conductivity
"Conductivity analysis was added at a daily monitoring frequency for the effluent and at a variable
frequency for the instream samples. The rationale for this change is not addressed in the Fact Sheet, and
the City of Gastonia requests that the conductivity monitoring requirement for the effluent and instream
sampling be removed."
Response:
The conductivity summary in Section 12 of the fact sheet has been updated to reflect the following:
"The Facility has industrial dischargers 15A NCAC 2B.0500."
Basis:
• The Facility has an inactive pretreatment program with one non -significant industrial customer
discharging into Eagle Road WWTP, Syncot Plastic.
• Voluntary conductivity sampling results and results of the expanded effluent scan raise concerns
about industrial discharges in WWTP. Conductivity is added, and Pretreatment staff will follow up
as needed.

3. Comment on Facility components list.
"The facility components listed in item 1 on page 2 of the draft permit do not correctly list the size of
components at Eagle Road WWTP. The correct sizes are: Aeration basin: 6.3 MG; Clarifiers: 690,000
gallons each; Chlorine contact basin: 94,000 gallons"
Response:
Thanks for noting this and providing additional information. The NPDES permit has been updated to reflect
the size of the components noted above. We took the flow capacity information from the Eagle Road Plant
Schematic on Page 36/86 of the application package. Please revise and update as necessary.
4. Comment on Part I Section A. (8.) 1 Reporting Requirements
"Section I A. (8.) 1. of this draft permit requires that "Until such time as the state's eDMR application is
compliant with EPA's Cross -Media Electronic Reporting Regulation (CROMERR), permittees will be
required to submit all discharge monitoring data to the state electronically using eDMR and will be
required to complete the eDMR submission by printing, signing, and submitting one signed original and a
copy of the computer printed eDMR ..." The City of Gastonia has previously been informed that signed
copies of the eDMR are no longer required to be submitted and asks that this section be removed if it is
no longer applicable."
Response:
Thanks for noting this language error; the NPDES permit has been updated to reflect the following:
"The Permittee shall report discharge monitoring data electronically using the NC DWR's Electronic
Discharge Monitoring Report (eDMR) internet application.
Monitoring results obtained during the previous month(s) shall be summarized for each month and
submitted monthly electronically using eDMR. The eDMR system allows permitted facilities to enter
monitoring data and submit DMRs electronically using the internet. The eDMR system may be accessed
at: https://deq.nc.gov/about/divisions/water-resources/edmr
If a permittee is unable to use the eDMR system due to a demonstrated hardship or due to the Facility
being physically located in an area where less than 10 percent of the households have broadband access,
then a temporary waiver from the NPDES electronic reporting requirements may be granted, and
discharge monitoring data may be submitted on paper DMR forms (MR 1, 1.1, 2, 3) or alternative"
5. Comment on Industrial Activity
"Section 1 of the Fact sheet for this permit states that none of the industrial customers in TRU's service
area discharge to Eagle Road. While there are no industrial customers in the portion of Gastonia/TRU's
collection system that discharge to Eagle Road WWTP, there is one non -significant industrial customer,
Syncot Plastics, in the portion of the City of Belmont's collection system that discharges to Eagle Road
WWTP."

Response:
We misunderstood the April 15, 2021, email from TRU, in which David Schellenberger stated, "None of
the industrial customers in Two Rivers Utilities' service area discharge into Eagle Road WWTP." Section 1
of the Fact Sheet has been updated as follows:
"The pretreatment program has been inactive since 2006. The Facility provided the June 2020 industrial
waste survey (IWS) for the entire area covered by the City of Gastonia's three WWTPs. One non -significant
industrial user (NSIU) in the City of Belmont (Syncot Fibers and Plastics — SIC Code 2299) discharges into
Eagle Road WWTP. Syncot Fibers and Plastics is regulated through the City of Belmont's pretreatment
program."
6. Comment on Fact sheet section 12. TN, TP, and conductivity.
"Section 12 of the fact sheet for Eagle Road WWTP lists information that is inconsistent with the draft and
current permits for the following parameters:
Response:
a. Conductivity: Monitor and Report is listed under "Current Permit Limits and Monitoring
Frequency" for instream samples at a variable frequency, but the current permit does not
have an instream conductivity monitoring requirement.
b. Total Nitrogen (TN): Under "Proposed Change" a MA limit of 6 mg/L is listed along with
comments in "Basis for Condition/Change". This is inconsistent with the current and draft
permits. The City of Gastonia asks that "No Changes" be listed for Total Nitrogen.
c. In Section 12 of the Fact Sheet for this permit under the parameter for Total Phosphorus,
a MA of 1 mg/L is listed for "Current Permit Limits and Monitoring Frequency" but that
limit was removed 12/31/2017. Monitor and Report should be listed in that section for
Total Phosphorus."
a. Instream and effluent Conductivity are listed in the draft permit. The Fact Sheet was
adjusted as explained in response to comment 2 above.
b. TN concentration limit language was adjusted in the fact sheet.
c. The Fact Sheet and NPDES permit were adjusted as explained in response to comment 1
above.

Comment from public member, Lisa Stroup:
Comment: "Because NPDES Permit NC0020184 and NC0006033 are Wastewater Treatment Plants in
Gaston County that discharges treated domestic and pretreated industrial wastewater to South Fork in
the Catawba River Basin; and includes Ammonia, biochemical oxygen demand, dissolved oxygen, fecal
coliform, pH, total residual chlorine, total nitrogen, total phosphorous, and total suspended solids are
water quality limited parameters in both permits. I request that more stringent requirements and testing
be implemented to further protect the water quality for citizens of this county and the State of NC.
Continuing to implement only a minimum requirement for testing and monitoring and reporting
requirements continues to place the public health, safety and welfare and the environment at undue risk
because of the cumulative impact of other nearby industrial facilities and wastewater treatment
facilities. NC currently has no regulations to avoid contamination and therefore has not adequately
provided effective measures to protect nor enhance the water quality of the State of NC water. We can
no longer accept the minimum requirements as sufficient protection for the public nor for the
environment."
Response:
Thanks for your comment. We appreciate public input and understand your concerns. We, NCDEQ
Municipal Permit Unit, follow and implement the current federal and state regulations to protect surface
water quality. We issue permits to dischargers with limitations on wastewater flow and constituents. This
process includes determining the quality and quantity of treated wastewater that the receiving stream
can assimilate, incorporating input from stream modeling, collaborating with Regional Office staff, and
evaluation of the discharger's location.
Where appropriate, the NPDES program establishes limits for flow (quantity discharged), conventional
pollutants (BOD, pH, TSS, fecal coliform, oil & grease, etc.), toxicants (metals, volatile organics, etc.), and
non -conventional pollutants such as ammonia and nutrients. For more information about the NPDES
process and links to forms, please visit the NPDES Permitting Process page.
Please let us know if you have any questions.